Funding News Edition: September 21, 2022 See more articles in this edition
Grantees, take note: You have 120 days after your grant’s period of performance end date to liquidate obligations by drawing funds from the Payment Management System (PMS). After 120 days, PMS will automatically reject requests to withdraw funds.
Put differently, you will lose access to your grant funds about 4 months after the project’s end date, so you need to pay all previously incurred expenses before then. This is an old rule, refer to 2 CFR Part 200, but recently NIH has had several instances of grantees caught unawares by its enforcement.
That deadline—120 days after the period of performance end date—is also the deadline for you to submit a final Federal Financial Report (FFR) for the award.
What If I Know I Will Need More Time?
You may request a no-cost extension if you will need additional time to fulfill closeout requirements (i.e., to prepare, revise, or amend financial reports). These requests will be reviewed on a case-by-case basis.
Most awards provide the grantee authority to extend the final budget segment of a previously approved period of performance one time for up to 12 months beyond the original completion date listed in the Notice of Award. The process for requesting a no-cost extension is detailed in our No-Cost Extension SOP. It’s imperative that you make this request before the last day of the approved period of performance, rather than during the liquidation period.
What If I Didn’t Realize I Would Need More Time
In certain circumstances, grantees may request payments from PMS beyond 120 days past the period of performance end date, and NIAID considers such requests on a case-by-case basis.
To make such a request, you must submit a prior approval request to the grants management specialist assigned to your award before submitting a payment request in PMS. In your prior approval request, list the PMS subaccount, NIH grant number, amount of funds being requested, and a justification for the late payment. You must also describe what actions your institution will put in place to prevent similar situations in the future.
Refer to Updated Process for Requesting Drawdowns Outside of the Liquidation Period for additional details. Keep in mind, NIH will show less leniency toward organizations that repeatedly request payments beyond 120 days.
Other Reminders
You cannot incur new expenses following your grant’s period of performance end date as a strategy to spend remaining funds in PMS.
Remember that grantees must submit the FFR through PMS, not eRA Commons, as explained in our January 21, 2021 article “Change of Platform for Federal Financial Report Submissions.”
Read Reminders of NIH Policies Related to Closeout for additional details, including instructions for reconciling an error discovered after FFR submission. Contact the grants management specialist assigned to your award if you have questions specific to your situation.