NIH’s Office of Policy for Extramural Research Administration (OPERA) is strengthening enforcement of grant closeout requirements. Already, if a recipient does not submit all required closeout reports within a year of the period of performance end date, Section 8.6 Closeout of the NIH Grants Policy Statement (NIH GPS) requires NIH to unilaterally close the grant and report the recipient's failure to comply with the terms and conditions of award.
As made clear in the January 23, 2024 Guide notice, NIH intends to strictly enforce its closeout policies.
NIH now reports unilaterally closed NIH awards as “Responsibility/Qualification” records under organizations’ profiles (“Entity Information”) within the System for Award Management (SAM.gov). NIH will also report unilateral closeout actions in SAM.gov retroactively, beginning with all unilateral closeout actions taken since January 1, 2023.
Recipients Are Responsible for Submitting Timely Closeout Reports
Recipients have up to 120 days after a project period end date to submit any required closeout documents, which may include the Final Federal Financial Report, Final Research Performance Progress Report, and Final Invention Statement and Certification.
Applicable closeout reports are considered delinquent 121 days after the project period end date. If final reports are still missing or inaccurate 180 days after a grant’s end date, the closeout status in eRA Commons will change from “Open for Closeout” to “In Unilateral Closeout,” at which point NIAID will take steps to unilaterally close the grant.
Keep in mind, even after submission of final reports, recipients must keep project records accessible for 3 years from the project period end date, as stated in NIH GPS Section 8.4.2 Record Retention and Access.
For more information on your responsibilities as a recipient, go to Final Reports for Grant Closeout.
NIH’s Commitment to Ensuring Compliance
Again, if you fail to submit timely closeout reports, NIH will unilaterally close the award and report the organization’s failure to comply with the terms and conditions of award. Should that happen, you may affect future funding for your organization.
Failure to correct recurring reporting problems may cause NIH to take corrective actions such as withholding future funding on new or noncompeting awards, or suspending or terminating awards, as described in NIH GPS Section 8.5.2 Remedies for Noncompliance or Enforcement Actions: Suspension, Termination, and Withholding of Support.
Direct questions about closeout policy to OPERA’s Division of Grants Compliance and Oversight at GrantsCompliance@od.nih.gov or 301-435-0949. For award-specific matters, contact the grants management specialist listed in your Notice of Award.