By Ashley Alexander & Vibeke Svensson
The NCURA Region II Meeting was held April 30 – May 3 in Saratoga Springs, New York. Research administrators from the Mid-Atlantic region were able to receive information through networking meetings and various sessions.
In March the revised Research Terms and Conditions (RTC) along with three supplement resources; Appendix A, Prior Approval Matrix/Appendix B, Subaward Requirements Matrix/Appendix C, National Policy Requirements Matrix, were released. The Research Terms and Conditions have been revised to reflect the Uniform Administrative Requirements, Cost Principles, Audit Requirement for Federal Awards, 2 CFT 200 (Uniform Guidance).
The links to the RTC and appendices can be found at: https://www.nsf.gov/awards/managing/rtc.jsp
The Prior Approval Matrix, Appendix A is an excellent resource to get a quick overview of the federal agencies requirements for approval. Currently NSF, DOE and NIH are the three agencies who have implemented the RTC. The remaining participating agencies are expected to following in the near future. In the below is a list of the agencies with their expected implementation deadline as listed below.
National Aeronautics and Space Administration (NASA): Implement the Research Terms and Conditions on new awards issued after Oct. 1, 2017.
National Institutes of Health (NIH): Research Terms and Conditions apply to all NIH grants and cooperative agreements with the exceptions noted in the NIH Agency Specific Requirements and is effective as of April 3rd, 2017.
National Science Foundation (NSF): All new NSF grants and funding increments on existing NSF grants to institutions of higher education and non-profit organizations will incorporate by reference the Research Terms and Conditions dated April 2017, and the NSF Agency Specific Requirements dated April 2017. Effective April 3, 2017.
U.S. Department of Agriculture/National Institute of Food and Agriculture (NIFA): The terms and conditions will apply to all awards (grants, cooperative agreements, and special projects) funded by NIFA except: 1) Capacity Programs; 2) the 1890 Facilities Program; and 3) the Small Business Innovation Research Program; as well as 4) awards to individuals as of June 2017.
U.S. Department of Commerce: Implement the Government-wide core set of research terms and conditions for all research financial assistance awards subject to 2 CFR Part 200, in addition to any Department and Bureau-specific terms and conditions that may apply. Commencing October 1, 2017,
U.S. Department of Energy (DOE): Implement the Research Terms and Conditions for all new grant and cooperative agreement awards made after April 3, 2017 to all organizations subject to 2 CFR 210 as implemented by 2 CFR 910.
U.S. Environmental Protection Agency (EPA): Apply the standard Research Terms and Conditions to research grants and cooperative agreements awarded by the Office of Research and Development with exceptions. The anticipated implementation date December 2017.
U.S. Department of Transportation/Federal Aviation Administration (FAA): The FAA Centers of Excellence Program will adopt the Standard Research Terms and Conditions with the negotiation of all new agreements beginning on or after October 1, 2017.
U.S. Department of Homeland Security (DHS): Apply the standard Research Terms and Conditions to new research grants and cooperative agreements beginning in fiscal year 2018, October 1, 2017.
The Federal Demonstration Partnership (FDP) held its Phase VI Meeting on May 10-12. The FDP “offers a forum for individuals from universities and nonprofits to work collaboratively with federal agency officials to improve the national research enterprise”. A wealth of information was shared among federal officials, faculty, and sponsored research administrators.
In one of the sessions I attended, the Grants Oversight and New Efficiency (GONE) Act was discussed. Effective January 28, 2016, the GONE Act’s goal is to close out all federal awards that have expired. Because of this act, the Office of Management and Budget (OMB) must submit a report to Congress by December 31, 2017, that:
- Lists each federal grant held by such agency
- Provides the total number in federal grant awards, including the number of grants by time period of expiration, the number with zero dollar balances, and the number with undisbursed balances
- Describes the challenges leading to delays in grant closeout
- Explains, for the 30 oldest federal grant awards, why each has not been closed out.
From the federal sponsor’s perspective, an award that has ended but not properly closed remains active in the federal agency’s system; thus, costing additional funds to keep the grant active. What was shared at the meeting is there are some awards in cash management systems that may have less than ten dollars remaining but have not been properly closed which causes administrative burden and additional cost to manage awards. For example, it was reported in a 2013 article “the federal government spent at least $890,000 on service fees to maintain empty accounts of expired grants. Although most cases are due to final financial reports not entered into cash management systems, others are due the lack of submitting final technical reports or other reports due at the end of an award.
Regarding award closeout, federal officials stressed the importance of a proper closeout. Closeout of an award is just as important than award receipt. Proactive steps should be taken to ensure proper closeout of an award. When there are any issues related to award closeout, universities should be in touch with Grants Management Specialists assigned as both parties work together for closeout. Effective communication is essential in properly closing out awards.
Federal officials at the FDP meeting stated the agencies are working on reports to send to recipients concerning awards that are affected. From an institutional standpoint, all involved in the grant administration can work proactively to identify those awards in the Payment Management System (PMS) that are active and work on taking appropriate action to close out the awards. As all involved in research administration are aware, failure to submit reports can ultimately prohibit the university from receiving additional funding.
For more information about the GONE Act, click on the following link: Grants Oversight and New Efficiency (GONE) Act.
For more information about FDP, click on the following link: Federal Demonstration Partnership.
 Congressional Research Service. (2016, January 28). S.1115 – GONE Act. Retrieved from Congress.gov Web site: https://www.congress.gov/bill/114th-congress/senate-bill/1115?q=%7B%22search%22%3A%5B%22%5C%22GRANTS+OVERSIGHT+AND+NEW+EFFICIENCY+ACT%5C%22%22%5D%7D&resultIndex=1
 Federal Demonstration Partnership. (n.d.). About Us. Retrieved May 19, 2017, from Federal Demonstration Partnership: http://sites.nationalacademies.org/PGA/fdp/PGA_054588
 Jernigan, S. (2016, February 3). President Obama Signs the GONE Act. Retrieved from Management Concepts Web site: http://blogs.managementconcepts.com/president-obama-signs-the-gone-act/#.WSL-puvysdU
Ashley Alexander, PhD, is the Assistant Director of OSP.
Vibeke Svensson, PhD, is a Grant and Contract Manager in OSP.