In general, sponsors must approve subcontracts not identified in the original budget. Appropriate paperwork from the proposed subcontractor must be included: a Subrecipient Statement of Collaborative Intent (SSCI) form signed by the subcontractor’s authorized institutional representative, a statement of work, and a budget and budget justification. If the subaward was not included in the original proposal, an Add-on subcontractor request ( see PG 12: Section 5. Contract Requests, a. Add-On Subcontracts) must be submitted to SPA through PEER.
VU SPA is using procedures laid out through the Federal Demonstration Partnership (FDP) best practices for Risk Assessment. Please reference the Federal Demonstration Partnership (FDP) website, specifically the Subaward Forms section and the Risk Assessment portion to learn more. The FDP Risk Assessment Tool is what has helped inform our decisions regarding ongoing subrecipient monitoring. The SPA process will be to send a Continuing Assessment Tool REDCap survey to both the Department and OCGA to answer themselves about working with the subrecipient. SPA will initiate this survey for non-FDP, foreign, and/or for-profit subrecipients.
Click on the link, if you would like to learn more about the FDP Continuing Assessment Tool document. It is the tool that we are using to collect information from the Department/PI and OCGA perspectives, which helps SPA assess any changes in risk on an annual basis.
We would like to offer to visit your college or department to provide training on this subject. Please contact us atSPA.Training@vanderbilt.edu to schedule a time for us to come meet with you.
Agency approval is not usually necessary when the PI of a federal award wishes to purchase a piece of equipment not originally identified in the budget. Unless Prior Approval is required, you will not go through SPA. If Agency Prior Approval is required, then contact your SPA Specialist who will help you decide what steps to take. If it is determined that a Prior Approval Request is necessary, then the request typically requires a scientific/programmatic rationale for the purchase, a cost breakdown, and, if possible, vendor quotes.
Prior approval is not required for a change of vendor or model for equipment included in the approved budget, nor for a change of 25% or less in the acquisition price of approved equipment. Purchasing equipment at the end of a project period is difficult to justify and will not normally be permitted.
After an award is made, changes resulting from circumstances not anticipated in the planning stages of the project are sometimes necessary. These changes can be programmatic or financial in nature. Some changes require the sponsor’s prior written approval, others may be authorized internally by Vanderbilt. See below for examples.
Refer to the sponsor’s regulations and award documents and contact your SPA representative with specific questions regarding such changes. Requests to sponsors must be authorized by SPA prior to submission to the sponsor.
Examples of programmatic and financial changes during the life of an award:
- Changes in the scope of work (SOW)
- Change of Principal Investigator or significant reduction of effort
- Changes/additions to collaborating institutions/subcontractors responsible for carrying out a portion of the SOW
- No cost extension of the budget or project period (extension of time without additional funds)
- For federal awards, the OMB Unified Guidance grants permission to an awardee to re-budget, except where there is a change in the SOW or the need for additional funding
- Non-federal awards may provide different thresholds for re-budgeting, for example by percentage or amount of deviation by budget category or line item, or stipulate that “substantial” deviation requires prior approval
- Carry-forward of funds from one budget period into the next within a project period
Changes under Federal Demonstration Partnership (FDP) Awards
The Federal Demonstration Partnership (FDP) is a cooperative initiative among certain federal agencies and institutional recipients of research funds. The FDP developed standard Research Terms and Conditions (RTC) now in use by several federal sponsoring agencies. Visit the Research Terms and Conditions page on the NSF website for an explanation of each of the Research Terms and Conditions as well as a link to each participating federal agency’s specific RTC.
See the Prior Approval Matrix to identify how various federal agencies have implemented these Research Terms and Conditions and the need for prior sponsor approval.
Vanderbilt utilizes PEER to review changes that may be institutionally authorized. See PEER Manual for directions on how to submit a request through PEER.
NIH is moving toward electronic submission of all Prior Approval Requests**, which include:
No Cost Extension requests
Change PD/PI requests
**Although current information states that either letter or electronic submission is available, If a link is available to submit Prior Approval Requests electronically, then SPA will make every effort to comply with NIH requirements in preparation for when electronic submission is mandatory. This may mean that your SPA Specialist will require additional information or alternate formats for this information to be submitted via eRA Commons. Your SPA Specialist will guide you in preparing documents for electronic submission.
Check this link for NIH specific information on submitting Prior Approval Requests electronically through eRA Commons.
NIH Research Performance Progress Report (RPPR)
Types of RPPRs
Progress reports document grantee recipient accomplishments and compliance with terms of award. There are three types of RPPRs, all of which use the NIH RPPR Instruction Guide.
- Annual RPPR – Use to describe a grant’s scientific progress, identify significant changes, report on personnel, and describe plans for the subsequent budget period or year.
- Final RPPR – Use as part of the grant closeout process to submit project outcomes in addition to the information submitted on the annual RPPR, except budget and plans for the upcoming year. Only the PI and Signing Official have access to the Final RPPR.
- Interim RPPR – Use when submitting a renewal (Type 2) application. If the Type 2 is not funded, the Interim RPPR will serve as the Final RPPR for the project. If the Type 2 is funded, the Interim RPPR will serve as the annual RPPR for the final year of the previous competitive segment. The data elements collected on the Interim RPPR are the same as for the Final RPPR, including project outcomes.
Submitting the RPPR
There is no RPPR form available for download. Submit RPPR data through the eRA Commons. The links for each type of RPPR are accessed through the Commons Status tab. The Interim RPPR link will also be accessed through the Commons Status tab. It will appear one day after the project segment end date, but before it has moved to closeout. The Final RPPR link will become available through the closeout module once the grant is eligible for closeout.
Only the project director/principal investigator (PD/PI) or their PD/PI delegate can initiate RPPRs. For multi-PD/PI grants only the Contact PI or the Contact PD/PI’s delegate can initiate the RPPR.
Signing officials typically submit the annual RPPR, but may delegate preparation (Delegate Progress Report) and submission authority (Delegate Submit) to the PD/PI. Signing Officials and PD/PIs are able to submit the Interim and Final RPPRs (no delegation needed).
COEUS Requirements for RPPR Submission of continuation awards
- Other Support reconcile document
- Unobligated Balance Spreadsheet Report
- IACUC Approval (if applicable)
- IRB Approval (if applicable)
- Effort Report
- The COEUS budget should match the reporting year award.
Sponsors require that the award be properly closed out at the PI’s prior institution before giving approval to transfer the award to the new institution. The prior institution must provide a final financial accounting with which the sponsor concurs and then formally relinquish the grant. The receiving institution may need to provide a revised budget. If Vanderbilt is the receiving institution then the Department should initiate the COEUS proposal for a "new" grant. The award balance is then transferred to the new institution. It is the PI’s responsibility to notify his/her Program Officer as soon as possible to alert them to any changes of this nature. No transfers will be made until the PI has completed all reporting requirements.
A transfer of a grant may involve the transfer of equipment purchased with sponsor funds. The transfer of equipment may be accomplished as part of the relinquishment of the grant, subject to sponsor approval.
In many cases, grants to be transferred to Vanderbilt from other institutions will have a lower Facilities and Administrative (F&A) rate than Vanderbilt's negotiated federal rate. In some circumstances Vanderbilt may choose to accept the previously approved F&A rate, with the understanding that this lower rate will be allowed only until the next competing continuation or renewal phase.
For more information on the Relinquishment process please see the Standard Operating Procedure for Relinquishment Statements.
NOTE: Pending proposals require formal transfer of ownership when the PI moves from one institution to another before a funding decision has been made. In this situation, the PI’s previous institution also relinquishes ownership of the proposal to the sponsor. The new institution then submits a revised budget (using its F&A rate), budget justification, and other pertinent forms as requested by the sponsor. In some cases the agency may require the PI to resubmit the proposal in its entirety.
Regardless if you need Prior Approval for a No-Cost-Extension (NCE) from the granting agency, SPA is involved.
Read the Sponsor’s guidelines for NCEs to determine if prior approval is needed.
If you are not sure what Prior Approval please review the information on the SPA Website.
1st No-Cost Extension to an NSF award:
- The process is initiated by the PI in Research.gov.
- NSF sends an email to SPA notifying SPA that the PI has made the request.
- If the PEER request has not been made - an email will be sent to the department Grant Manager to enters the request into PEER using the “Request for First No-Cost Extension” link. (Complete all fields in the “Request for First No-Cost Extension” window)
- The SPA Specialist logs into Research.gov to review, approve & submit the NCE request.
- PI receives notification when NCE approved
1st No-Cost Extension to an NIH award:
- Request for NCE is initiated by the Department through PEER using the “Request for First No-Cost Extension” link. (Complete all fields in the “Request for First No-Cost Extension” window)
- PEER sends the request to the PI for approval.
- Once the PI approves in PEER, the request is routed to SPA.
- The SPA Specialist reviews the request and submits the NCE request via eRA Commons.
- PI receives notification from Commons that the NCE has been submitted
1st NCE - OTHER AGENCIES (non-NIH, non-NSF)
- Depending on Sponsor Guidelines, VU may / may not have to approve PI’s request for NCE. Contact SPA Specialist with questions after reading sponsor guidelines.
Request for a 2nd NCE to ANY agency:
- Review Sponsor guidelines to determine if 2nd NCE allowed.
- If allowed, what method? Written request, Agency website/PI initiated, PI e-mail
- NSF – PI initiated via Research.gov
- NIH – Written request to include budget and justification
- Other – abide by guidelines of sponsor
- Notify SPA of 2nd NCE request via SPA mailbox or contact SPA Specialist.
- NCE request will be logged into PEER by Grant Coordinator for Specialist follow-up.