Lost in MRB III
Answer---You are not alone Lost in MRB III and yes, there are implications. Let’s take a closer look….
Last but Not Least
“Close out” is the final stage of a funded project. One of the many important duties performed by the PIs, grant administrators, and OSP is final administrative close out of grants and cooperative agreements. Preparation for closeout should begin three months prior to the end date of the grant in order to accurately forecast expenses and to adjust any entries that need to be made. This is also the best time to discuss with your faculty member whether or not an extension will be needed. In order for a NIH grant to be extended 12 months beyond the awarded project period the following must apply and can be approved by OSP without NIH approval:
- no additional funds are required to be obligated by the NIH awarding office,
- the project’s originally approved scope will not change, and
any one of the following applies:
- Additional time beyond the established expiration date is required to ensure adequate completion of the originally approved project.
- Continuity of NIH grant support is required while a competing continuation application is under review.
- The extension is necessary to permit an orderly phase-out of a project that will not receive continued support.
The fact that funds remain at the expiration of the grant is not, in itself, sufficient justification for an extension without additional funds to properly finish.
If the PI determines that a no-cost extension is not needed, than there are certain steps that must be taken in order to properly closeout the award. These steps are as followed and must be completed within 90 calendar days after the last day of the final budget period:
- submission of a Final Financial Status Report,
- submission of a Final Progress Report, and
- submission of a Final Invention Statement and Certification
All three of these items can be submitted via NIH Commons. Contact OSP for instructions.
It is important to remember that unless the Grants Management Officer of the respective awarding agency approves an extension to this 90-day reporting window in writing, VU must submit the final reports within the given timeframe. In understanding how important the submission of these documents is, please consider and remember NIH’s compliance policy regarding closeouts and the implications of being non-compliant can cause:
"Failure to submit timely and accurate final reports may adversely affect future funding to the organization and/or awards with the same principal investigator (PI). Accordingly, NIH may impose sanctions on institutions that fail to correct recurring reporting problems. Such sanctions may include restriction of facilities and administrative (F&A) costs, removal of authorities, delay or withholding of further awards to the project or program, removal from participation in NIH-funded awards under the Federal Demonstration Project, and/or designation as a high-risk grantee."
It is important for everyone to be mindful of these reporting requirements as it may affect not only your PI, but also the institution as a whole. Please remember to carefully read each Notice of Grant Award for the specific terms and conditions and the next time your faculty member comes to you with exciting news of a new award, be sure to remind him/her of those closeouts that are still pending.
So, now you know…