eSubmission News and Updates

Submitting Subaward Budgets That Are Not Active for All Periods of the Prime

Recently, our developers corrected our system code to enforce the existing requirement that non-zero effort must be listed for each Senior/Key person listed on the SF424 (R&R) Budget subaward forms. Since the correction, if a Sr/Key person is listed on the budget form and no effort is listed, the following error message is triggered:

“Senior/Key Person {0}, listed on the 424 RR Detailed Budget Page for budget year {1}, must include effort of a value greater than zero in calendar months, academic months, or summer months. Note: use either calendar months or a combination of academic and summer months.  For information about calculating person months, see http://grants.nih.gov/grants/policy/person_months_faqs.htm. ({2}) – Error”

The Grants.gov forms do not allow for an “empty” budget period and it is no longer possible to submit a subaward budget with zero effort to skip a budget period. So, how do you submit a subaward budget when the subaward is not active for all the budget periods of the prime?

First, you need to fill out the subaward R&R Budget form. The subaward budget form should include only the number of periods for which the subaward is active. The budget period start/end dates reflected in each period should reflect the correct prime budget period start/end dates.

For example, suppose the prime has filled out a budget form with the following periods:

-         period 1    Jan 1 2008 – Dec 31 2008
-         period 2    Jan 1 2009 – Dec 31 2009
-         period 3    Jan 1 2010 – Dec 31 2010
-         period 4    Jan 1 2011 – Dec 31 2011
-         period 5    Jan 1 2012 – Dec 31 2012

Now, suppose there is a subaward that performs in support year 1 and does not become active again until support year 4. The subaward can fill out the first two periods of their budget form as follows:

-         period 1   Jan 1 2008 – Dec 31 2008   (dates correspond to prime period 1)
-         period 2   Jan 1 2011 – Dec 31 2011   (dates correspond to prime period 4)

It is not necessary that the budget period numbers between the prime and subaward match; the correlation is reflected in the dates. Do be careful, however, that the dates exactly match what is listed for the period in the prime budget. We are exploring long term solutions to match the period numbers between the prime and subaward, but the forms do not currently support it.

Next, you should document in both the cover letter and the subaward budget justification that the subaward is only active for specific periods of the prime. Appropriate NIH staff has access to the cover letter and reviewers have access to the budget justification. This documentation will make the date correlation immediately apparent and will help avoid any confusion.  

Unfortunately, we have discovered that the system validation used to calculate the direct cost limits for budget periods (excluding subaward Facilities & Administration Costs) does not match up the subaward and prime budget period dates. This may cause the warning for exceeding $500K in a budget period to inappropriately trigger. If you know you have not exceeded the $500K limit in any budget period, the warning can be ignored. However, if you end up submitting the application again (e.g. to address other error/warnings), please add a note in the cover letter explaining why the $500K issue was triggered. The Division of Receipt and Referral will need to manually check the validity of the warning. The cover letter is their first check point and your note can save them some investigation time. We will address this issue as soon as we can, but realistically a fix will not be available until the end of the year.

More and more organizations are creating their own system-to-system solutions or using commercial service providers to send application data directly to Grants.gov as an alternative to using Grants.gov’s downloadable forms. For the July 5 submission deadline, nearly 18 percent of applications were submitted using system-to-system solutions (up from 10 percent for the February 5 submission deadline) and 97% of the applications were error-free within two submission attempts (compared to 92% for forms-based submissions over the same period). To date, more than 100 organizations have submitted applications to NIH using system-to-system solutions.

Hope you’re enjoying your summer!