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Reporting and Record Retention Guidance for NIH Grantees

NIH requires all Financial Status Reports (FSRs) (domestic and foreign) due on or after 10/01/2007 to be submitted using the electronic FSR system located in the eRA Commons. This includes all initial FSRs being prepared for submission and any revisions being submitted or re-submitted to NIH. For more information about this process, see NOT-OD-07-078.

Foreign grantees must submit annual Financial Status Reports (FSRs) on Standard Form SF-269, in U.S. dollars, whether or not they are under Streamlined Noncompeting Award Process (SNAP). This is due to the fact that foreign grantees are not paid through the Payment Management System (PMS) and, therefore, do not submit the SF-272 (which the National Institutes of Health (NIH) uses in lieu of the annual FSR for domestic awards under SNAP). The currency rate in existence at the time the FSR is prepared should be used in preparing the report. Record retention requirements are the same as those for domestic grantees.

Grantees generally must retain financial and programmatic records, supporting documents, statistical records, and all other records that are required by the terms of a grant, or may reasonably be considered pertinent to a grant, for a period of three years from the date the annual FSR is submitted. For awards under SNAP (other than those to foreign organizations and Federal institutions), the 3-year retention period will be calculated from the date of the FSR for the entire competitive segment once submitted. Those grantees must retain the records pertinent to the entire competitive segment for three years from the date the FSR is submitted to NIH.

Foreign organizations and Federal institutions are required to submit annual FSRs for all awards, including those under SNAP, and must retain these records for a period of three years from the date of submission of the annual FSR to NIH. See 45 CFR 74.53 [PDF] and 92.42 [PDF] for exceptions and qualifications to the 3-year retention requirement. Those sections also specify the retention period for other types of grant-related records, including F&A cost proposals and property records. See 45 CFR 74.48 [PDF] and 92.36 [PDF] for the record retention and access requirements for contracts under grants.

If you have funded FIC grant or cooperative agreement and have questions about filling out the FSR form, you can contact Valerie Thomas, Office of Financial Management (OFM), NIH at 301-402-9123 or 301-402-5338.