Grant-Admin-News: New NIH Grant Policy Statement

[Research Services <Research_Services@orsa.uoregon.edu>]

REVISED NIH GRANTS POLICY STATEMENT AVAILABLE

The National Institutes of Health (NIH) has issued a revised Grants
Policy Statement (NIHGPS) dated 3/1/2001, which is effective for all NIH
grants and cooperative agreements with budget periods beginning on or
after March 1, 2001.   The NIHGPS is available in both HTML and Adobe
Acrobat PDF formats at
http://grants.nih.gov/grants/policy/nihgps_2001/index.htm.  Copies of
the revised NIHGPS will not be printed or mailed.

The 3/01 NIHGPS is effective for all NIH grants and cooperative
agreements with budget periods beginning on or after March 1, 2001, and
will supersede, in its entirety, the NIH Grants Policy Statement dated
10/98 as a standard term and condition of award.  The NIHGPS published
in October 1998 remains the standard term and condition for all grants
and cooperative agreements with budget periods that began between
October 1, 1998, and February 28, 2001.

Part I of the revised NIHGPS provides a glossary of commonly used terms;
describes NIH and its relationship to other organizations within the
Department of Health and Human Services (HHS); specifies grantee, NIH,
and other HHS staff responsibilities; outlines the application and
review processes; and explains the various resources available to those
interested in the NIH grants process.

Part II serves as the terms and conditions that are incorporated by
reference in all NIH grant awards.  It also specifies, in separate
sections, requirements that pertain to construction grants; training
grants and fellowships; conference grants; consortium agreements; grants
to foreign and international organizations (and domestic grants with
substantial foreign components); grants to Federal institutions and
payments to (or on behalf of) Federal employees; grants to for-profit
organizations; modular grants; and research patient care activities.

Part III contains general contact information to aid the reader. This
format allows general information, application information, and other
types of reference material to be separated from legally binding terms
and conditions that are contained in Part II.

Notable policy changes that are implemented with this NIHGPS include:

1.  The separate requirement for approval of "significant rebudgeting,"
which was eliminated for Modular Grants, has been eliminated for all
grant types, effective immediately.  It is now incorporated as an
indicator of a change in scope.  This change eliminates the need to
reply to question #2 of the four streamlined noncompeting award process
(SNAP) questions.

2.  The term "collaborator" has been changed to "co-investigator."  This
change is intended to more accurately describe the role of individuals
who are involved with the principal investigator (PI) in the scientific
development or execution of the project.  This change in terminology
does not change the role and/or responsibilities of the PI as detailed
in the NIHGPS or the PHS 398 application.

3.  The criteria to allocate costs normally assignable to multiple
projects ("closely related work") has changed.  A grantee may allocate
costs normally assignable to multiple projects to one of those projects
or else treat multiple projects as a single cost objective regardless of
the funding IC or whether the awards involve the same or different PIs.
However, identifying projects as "closely related" continues to be a
prior approval requirement.

4.  For grantees subject to OMB Circular A-21, "Cost Principles for
Educational Institutions," the 10/98 NIHGPS states that grantees subject
to OMB Circular A-21 may not rebudget from direct costs to accommodate a
facilities and administrative (F&A) rate increase unless the rate in
effect at the time of award was provisional.  This requirement is now
eliminated from the NIHGPS.  Grantees may rebudget between direct and
F&A costs (in either direction) without NIH prior approval, provided
there is no change in the scope of the approved project.

5.  Transferring performance of substantive programmatic work to a third
party through a consortium agreement or subcontract does not require
prior NIH approval unless it results in a change in scope or the third
party is a foreign organization or component.  The addition of a foreign
component requires prior approval for all recipients, regardless of
terms of award.

6.  A statistical sampling basis is now acceptable for physical
inventory of equipment.

7.  A list of administrative actions that require prior NIH approval is
provided in table format.  Note that the approval requirements vary
depending on type of award terms and conditions that apply.  Expanded
Authorities allow for most changes without prior approval of NIH; grants
not under the Expanded Authorities or FDP are more restrictive and
require prior approval for nearly all changes.  All requests for NIH
approval must go through ORSA and are due in NIH no later than 30 days
before the proposed change.

8.  Clarifying language on the use of 1099 forms for both fellowship and
training grants is included.

9.  The revised NIHGPS contains an explicit reference that it is the
grantee organization's responsibility to ensure that all sites engaged
in research involving human subjects have an appropriate OHRP-approved
assurance and IRB approval of the research, consistent with 45 CFR 46.

10. A continued and increased emphasis on timely and accurate reporting
is reflected throughout the document.

Contact ORSA at 6-5131 with any questions or for assistance in applying
the policies to a particular grant.


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