NIH Modular Research Grants
Overview
NIH Modular Grant Process
Update November 18, 2004
NIH Modular Grant application and award procedures were
implementated for the June 1, 1999 submission deadline. NIH
data indicate that almost 90 percent of competing individual research
project grant (R01) applications request $250,000 or less in direct
costs. On the basis of this experience, the size of the modules
and the maximum of $250,000 direct costs each year were selected
as criteria for Modular applications.
Current guidelines for Modular Grant applications are found on the
NIH web at http://grants.nih.gov/grants/funding/modular/modular.htm.
Below are specific items to include or exclude for this type of
application. Details for completing the PHS 398 (rev.9/04) application
form are found at http://grants.nih.gov/grants/forms.htm.
Be sure to make the following adjustments for Modular applications.
APPLICATION FORMS NOT SUBMITTED IN MODULAR APPS:
1. Detailed budget for the initial budget period (form page 4)
2. Detailed budget for the entire proposed period of support (form
page 5)
3. Detailed budget justification (form page 5)
4. Other Support pages
REQUIRED INFORMATION IN MODULAR APPS:
- Form Page 1: Face Page Blocks 7a and 8a must
show direct cost amounts requested in $25,000 modules up to $250,000
per year of the grant (e.g., "$175,000) exclusive of subaward
F&A. Use the internal UO Modular spreadsheets to help prepare
your budget and derive the numbers to put in these fields.
- Form Page 2: Description, Performance Sites, Key
Personnel, Other Significant Contributors, and Human Embryonic Stem
Cells
- Form Page 3: Table of Contents: Use "NA" for
page numbers for Detailed Budget and for Other Support.
- Modular Budget Format Page (was
form page 5)
- Typically, the number of modules requested will remain constant
through the entire budget period. Routine escalation for future
years is no longer permitted.
- Personnel: the role of ALL personnel should be described
by position, role, and level of effort . The percentage of
effort shown on the Modular Grant Budget Justification page
for all personnel should distinguish between academic year
and summer effort (for faculty with 9-month appointments).
No individual salary information should be in the budget. However,
the salary base and FTE must be in the detail budget reviewed
internally by ORSA. For personnel whose salaries exceed the
NIH salary cap, the cap should be used when calculating the
number of modules needed. Increase the cap amount by 3% for
out-year calculation. Include consultants and any TBA "to
be appointed" positions.
Note that any effort reported that is not directly charged
to the grant will be considered official costshare and must
be documented and reported throughout the project period.
- Consortium and Contractual (including Subcontracts): show
an estimate of Total Costs (Direct plus F&A) rounded to
the nearest $1,000 (subcontracts are not awarded in $25,000
modules). For each key individual/organization listed, the
role and percent effort should be provided. Each collaborating
institution must be indicated as foreign or domestic. The total
consortium/contractual costs should be included in the overall
requested modular direct cost amount.
- If there are subcontracts involved, submit the following
to ORSA for review and approval along with the UO budget,
for each subcontract:
- Detailed budget for Year 1 (spreadsheet acceptable)
- Multi-year budget, by major category (spreadsheet
acceptable)
- Statement of Work (to be done by subcontractor)
- Consortium letter (indicating approval of the proposal
by the subcontractor's sponsored projects office and
their willingness to enter into a consortium arrangement
if the project is funded.
- Variation in the number of modules requested in different
years should be described and justified, without providing
additional budget information. For example, purchase of equipment
in year 1 may result in a greater number of modules being requested
in year 1 than in subsequent years.
- Biographical Sketch Page (form page 6): expanded to4 pages
to include additional required information such as:
- Information on research projects relevant to the submitted
application (ongoing or completed during the last three years)
of the Principal Investigator and other key personnel, including
consultants (see sample bio sketch in PHS398). List each
project by agency and award number. Include individual's major
goals and responsibilities for each project.
- Do not include a list of all current and pending support with
award amounts. This will be requested by NIH staff "just
in time" of an award.
- Resources Format Page
- Checklist: Complete as usual, except for
F&A base in 3.a. and 3.b. The amount of base must be shown for
each year and is derived as follows:
- Determine the total direct costs based on the number of modules
requested each year (e.g., $175,000 yr 1, $150,000 yr 2, $150,000
yr 3) plus subaward F&A
- Exclude any cost items normally excluded from the F&A calculation,
such as equipment, graduate tuition, and subcontracts in excess
of the first $25,000, for each year (e.g., $175,000 minus $25,000
equipment in yr 1 leaves $150,000 as the base)
- Show the computed F&A costs for each year
- The grand total F&A cost calculation is entered automatically
on the form.
- UNCHANGED FROM STANDARD 398 APPLICATION:
All other components of the application are still required (for
example, Human Subjects information).
PEER REVIEW OF MODULAR APPLICATIONS:
As part of the Modular application initiative, NIH has changed the focus
of budget review from an examination of annual categorical budgets to
an evaluation of the total resources needed to complete the project.
Reviewers should consider the entire proposed research project and the
total direct costs needed to complete the project in the recommended
period. Based upon the reviewer's understanding of the research proposed
and the costs and services associated with such research, the annual
recommended budgets should be in modules of $25,000. In addition:
- Budget adjustments must be made in modules. If in the judgment of
the reviewers, the amount requested is too large for the work proposed,
the number of modules should be reduced. These reductions do not have
to be based on reductions of specific items, but rather can be made
generally based on overall funds requested.
- If changes in staffing, percent effort, specific aims, consortium
arrangements, etc. are recommended, but a cost in modules can not
be estimated, recommendations should be described in the budget section
without assigning an amount. Institute staff will request the specific
budget information and will adjust the budget at the time an award
is made.
- Reviewers should not address scientific and budgetary overlap issues
during the initial review. NIH staff will address these issues. Complete
and up to date Other Support information will be required and therefore
requested by Institute staff from applicants being considered for
awards. The Institute's scientific and grants management staff will
review this information and make the necessary administrative and/or
budgetary adjustments. These issues are the responsibility of Institute
staff and NIH will ensure that these actions are carried out. These
actions by staff are essential to the management of the Institute's
grant portfolio.
NON-COMPLIANT GRANT APPLICATIONS:
Applications not in compliance with Modular application instructions
will be handled as follows, effective May 4, 2001:
- The PI will be contacted and given four (4) business days to correct
the inconsistency.
- If the application cannot be corrected in that time period, the
application may be deferred to the next review cycle.
- If reviewers or other NIH staff identify non-compliant applications
later in the review process, applications may still be returned to
the institution or deferred at that time.
An application will be considered NON-COMPLIANT if:
- The requested direct cost budget is not in modules of $25,000
for all years of support for requests up to $250,000 direct costs
per year, exclusive of subaward F&A.
- detailed itemized categorical budget is provided.
- The budget justification page includes an itemized justification
for one or more of the following cost categories: equipment, supplies,
travel, other expenses, etc. but the number of modules requested
in each year is the same. Only information intended to explain the
request for a different number of modules in one or more years is
acceptable.
- Other support pages are supplied, in addition to or in the absence
of the section in the Biographical Sketch identifying "research
projects ongoing or completed during the last three (3) years."
- The bio sketch lists "current and pending support"
instead of or in addition to the required information for the bio
sketch
AWARD ISSUES:
- NIH staff will request an updated Other Support report for key
personnel "just-in-time" (JIT) to issue an award.
- If human research subjects were indicated in the project, NIH
staff will ask the PI to prepare and submit a letter describing
the education in human subject protection completed by each person
listed as "key personnel" in the proposal. The following
statement must be included in the letter "All key personnel
who are involved in the human subjects portion of the project [list
names here] have successfully completed the NIH on-line tutorial
entitled Protection of Human Research Subjects Computer Based Training
for Researchers." Institutional endorsement is required on
the letters so they must be sent to ORSA for review and counter
signature.
- The Scientific Review Group (SRG) may adjust the requested budgets.
Any overall adjustments by the SRG must be made in modules. In addition,
the reviewers may recommend specific budgetary changes that are
described in the summary statement, but cannot be reflected in a
modular reduction. In these cases, Institute staff will obtain the
necessary cost information prior to any award.
- The awarding Institute may adjust the amount to be awarded based
on identified overlap and/or a requirement to meet its current management
objectives. UO Modular awards have been received with varying reductions
from the amount proposed: zero reductions for three grants; 2% to
31% cuts for several grants; 1 module cut in years 4 and 5 for one
award; 5 years reduced to 4 years with additional minor dollar reductions
for four awards. Awarding Institute staff may request a detail budget
if they believe it will help in their review.
- Modular Awards are made without categorical budget amounts, except
for total direct, total F&A, and total costs each year. However,
the UO will set up the new grant account with budgeted categories
based on the proposal budget spreadsheet used and approved at the
time of submission.
- This change in the award process for Modular Awards does not eliminate
the applicability of the Cost Accounting Standards or the need for
sound fiscal management practices. The expectation remains that
costs incurred on sponsored projects will continue to be reasonable,
allowable, allocable and consistently treated. Expenses must continue
to be charged to appropriate account codes. In particular, personnel
effort must continue to be properly charged and reported, consistent
with award commitments and the NIH salary cap.
- Costs are monitored by UO and the NIH by the rate of expenditure
(cash draw down) in relation to the proposed scope of work and completion
of scientific aims.
- There is no longer a requirement for prior approval by the agency
for "significant rebudgeting" which occurs when expenditures
in a single direct cost budget category deviate (increase or decrease)
from the categorical commitment level established for the budget
period by more than 25 percent of the total costs awarded. The exception
is when significant rebudgeting changes the scope of the approved
project. When in doubt as to whether significant rebudgeting constitutes
a change in scope, PIs should discuss the issue with a program officer
and with ORSA prior to the change.
- There is no change in the NIH policy on carryover of unobligated
balances. For awards under the Streamlined Noncompeting Award Process
(SNAP), funds are automatically carried over and are available for
expenditure during the entire project period. However, under those
awards, the grantee will be required to indicate, as part of its
noncompeting continuation request, whether its estimated unobligated
balance (including prior year carryover) is expected to be greater
than 25 percent of the current year's total budget. If so, the grantee
must provide an explanation and indicate plans for expenditure of
those funds if carried forward. Exceptions to the automatic carryover
include funds restricted in an award notice or awards that are not
under expanded authorities.
UNIVERSITY OF OREGON PROCEDURES:
GENERAL POLICY
In response to the NIH Modular Grants concept, the University of
Oregon has determined that the following procedures will be followed
for submission of applications under this model. These procedures
will help ensure that 1) adequate support is being requested to
accomplish the proposed activities; 2) institutional rates for
salaries, fringe benefits, tuition, and other costs are included
at appropriate levels; 3) subcontractor costs are appropriate
and approvable; 4) exclusions from the direct cost base are accurate
for calculating Facilities and Administration (F&A) costs;
5) the institution complies with applicable cost principles and
meet Cost Accounting Standards; and 6) project costs are well
managed over the life of the grant.
BUDGETS
The Office of Research Services and Administration (ORSA) will continue
to check budgets to the extent of detail requested below. The
budget should be prepared for each year to provide a grand total,
from which an average year budget can be determined. The total
amount of direct costs, including one-time special costs such
as equipment, divided by the number of years will result in an
average annual amount. The next highest module level should be
your request level for each year.
A
sample modular budget is available on this web
site and in E-PCS.
A blank
modular budget spreadsheet is available for you to save on
a local drive and use for future proposals. If you do save a copy,
please rememeber to check our website for updates.
The ORSA spreadsheets for the Modular budgets figure the annual
average direct costs automatically and give the total number of
modules to request for direct costs, plus any subaward F&A (indirect)
costs, plus the UO F&A, for a total budget request.
CHECKLIST
This form is submitted with the proposal and includes information
on Facilities and Administrative (F&A) costs, formerly referred
to as indirect costs. The base amount for figuring F&A costs
must be shown for each year of the project and should reflect
all exclusions from the total direct cost modules requested, using
the UO's rate agreement. Then the total F&A costs are calculated
on the base using the appropriate F&A rate (contact ORSA if
you are unsure of the correct rate to apply). The UO's latest
F&A agreement is
dated 5/17/04.
Questions concerning the NIH Modular Grants Program or UO policies
and procedures should be addressed to ORSA at 6-5131.
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