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  • 1.  New NIH GPS and existing awards

    Posted Tue May 12, 2015 09:22
    This message has been cross posted to the following Discussions: Global Community and International Region .
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    We are wondering how you are treating existing awards with the new guidance implementation. It was our understanding that the new rules apply to grants awarded after the 26th December 2014 and not to new payments for awards where the notice of award was made before this time. Some insight here would be much appreciated! Thanks, Laura
     



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    Laura Plant Fuentes
    US Grants Coordinator
    Karolinska Institutet
    Stockholm, 17177
    (085) 248-7649
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  • 2.  RE: New NIH GPS and existing awards

    Posted Tue May 12, 2015 11:50

    Laura,

    As I understand it, NIH is applying Uniform Guidance (UG) to all new Notices of Awards (NOA) issued after 12/26/14, regardless of whether it's a new award or a non-competing continuation.  Since the NIH issues new NOAs for all new budget periods (except for Multi-Year Funds), all budget periods starting after 12/26/14 would fall under the new UG.  If the NOA references 45 CFR Part 75, then the new guidelines are applicable.

    I do want to point out that the application of UG to incremental funding seems to be an agency-by-agency decision.  At the FDP meeting in January, one of the agencies (I believe it was the Department of Defense) indicated that they would not be switching to UG on incremental funding periods issued after 12/26/14. 

    -Ryan

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    Ryan Dodd
    Director
    Southern Illinois University at Edwardsville
    Edwardsville, IL
    618-650-5199
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    Original Message


  • 3.  RE: New NIH GPS and existing awards

    Posted Wed May 13, 2015 03:37

    Thanks Ryan. I was not aware that it would apply to the continuation periods of existing grants. I will continue to investigate this and search out the new NoAs that were sent to the Primes where we are subawardees.

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    Laura Plant Fuentes
    US Grants Coordinator
    Karolinska Institutet
    Stockholm, 17177
    (085) 248-7649
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    Original Message


  • 4.  RE: New NIH GPS and existing awards

    Posted Thu May 14, 2015 16:47

    We interpret the Guidance to apply to all new funding after December 26.  In Section 200.111, the Guidance says it will be in effect for "all Federal awards or funding increments".  We think this means Federal funding under new Awards and new funding increments under existing awards.  We are not applying it to non-funding modifications such as no-cost extensions.

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    Jeffrey Newman
    Director, Contract & Research Administration
    Vanderbilt University
    Nashville, TN
    615-322-2476
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    Original Message


  • 5.  RE: New NIH GPS and existing awards

    Posted Fri May 15, 2015 12:20

    NIH has a FAQ list that may be helpful = http://grants.nih.gov/grants/policy/faq_grants_uniformguidance.htm

    Here is some of the information:

    B. Applicable Regulations and Notices of Award

    1.  
      ExpandMy Notice of Award (NoA) was issued prior to December 26, 2014. Which HHS regulations apply?

      The pre-Uniform Guidance regulations would apply. That is, 45 CFR Part 74 or 45 CFR Part 92—as applicable.

    2.  
      ExpandI received an NoA prior to December 26, 2014. I subsequently received a revised NoA to name a replacement PI after December 26, 2014. Which HHS regulations apply?

      Since the revision did not include additional funds, the pre-Uniform Guidance regulations would apply. That is, 45 CFR Part 74 or 45 CFR Part 92—as applicable.

    3.  
      ExpandI received a NoA on or after December 26, 2014 with funding for a new (or renewal) project grant. Which HHS regulations apply?

      The new regulations, 45 CFR Part 75, would apply along with the NIH Interim General Grant Terms.

    4.  
      CollapseI received a NoA on or after December 26, 2014 with funding for the next budget year of a continuing award. Which HHS regulations apply?

      Since a new increment of funds was received, the new regulations at 45 CFR Part 75, would apply along with the NIH Interim General Grant Terms. The new regulations and NIH Interim General Grants Terms will also apply to any previous fiscal year funds that are uncommitted or unobligated (carryover) as of the Federal award date.



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    Elizabeth Brittan-Powell
    Director, MPowering the State Joint Collaborations
    University of Maryland College Park
    College Park, MD
    301-405-1459
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    Original Message