In 2011, the Federal Demonstration Partnership (FDP) created a PHS Financial Conflict of Interest (FCOI) Clearinghouse as a mechanism for FDP member and non-FDP member institutions to document that they had a PHS FCOI compliant policy in place. This repository allowed participants to forego the exchange of thousands of individual transaction-specific documents. As of January 2016, 962 institutions are listed in the FCOI Clearinghouse. The success of this initiative led to the concept of an expanded Clearinghouse that would contain audit, demographic, and fiscal information needed by pass-through entities (PTEs) when they are issuing subawards. The need for a national repository was exacerbated by release of the Uniform Guidance, which expands subaward risk assessment and monitoring obligations. Many institutions created “Subrecipient Commitment Forms” to collect such data, but the proliferation of many different forms collecting mostly similar information has underscored the need for national consistency and a more efficient process.
The CDC and NIH have been transitioning to Payment Management System (PMS) subaccounts (also known as “P accounts”) in response to a U.S. Department of Health and Human Services (HHS) directive to Agencies intended to enhance financial data integrity and financial closeout for all awards. The CDC and NIH will continue transitioning payment for all domestic awards with new document numbers from PMS pooled accounts (G accounts) to P accounts until September 30, 2016. As of October 1, 2015, NIH will utilize only P accounts for awarding grant funds. Every grant that is awarded funding in FY 2016 (whether it be in the first, second, third or fourth quarter of FY 2016) will be in a P account.
NIH has recently released a memo (below) indicating the ASSIST system now has the functionality to prepare and submit R03 and R21 grant applications. Despite the new function, JHURA has decided that these application types should continue to be prepared and submitted system-to-system using the Coeus interface. In doing so, the University ensures it meets its compliance obligations, and JHURA and ORIS have the ability to provide better support in case issues arise during submission. If you have any questions, please contact your grants associate.
[Occasionally, we like to revisit posts from days gone by that either (1) are always relevant, or (2) are the subject of recent questions received by our office. In today’s From The Vault, we look at the differences between grants and contracts.]
On January 26, 2015, the National Science Foundation (NSF) will implement changes in FastLane to support the revised version of the Proposal and Award Policies and Procedures Guide (PAPPG) and to run additional automated compliance checks on proposals.
No matter how much time we spend working within COEUS, there are always those instances where we’re unsure how a particular action should be designated. Is it a Supplement or a Continuation? Administrative Action?