Frequently Asked Questions

Are investigators from federal agencies eligible to apply for ARRA Awards?
In general, Federal institutions are eligible to apply for NIH grants, including research project grants. However, special policies apply to awards to Federal agencies. They are described at http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part13.htm.

Federal institutions also must meet the eligibility requirements of the grant program from which support is sought. However, according to the NIH Grants Policy Statement, PHS organizational segments, other than IHS hospitals, may receive NIH grant support under exceptional circumstances only. NIH does not intend to classify ARRA funding as an "exceptional circumstance"; therefore, the standard rules would apply. CDC and FDA employees can collaborate, but would not be eligible for direct extramural grant funding from NIH.

Are foreign scientists working at domestic institutions eligible to be Principal Investigators, Key Personnel, and/or other personnel supported by an ARRA Award?
Yes, foreign nationals working in the US are eligible to work and be compensated with ARRA provided they are employed by a domestic institution and are in the country under valid visas. It is the grantee institution’s responsibility to assure that an individual’s visas will allow them to remain in this country long enough for them to be productive on the research project. NIH does not provide guidance on or assess the different types of visas. Grantee organizations are expected to have consistently applied policies in place to address this area.

There is a restriction in Section 1611 of ARRA that applies to institutions receiving Troubled Asset Relief Program (TARP) funds--primarily financial institutions. However, unless a NIH grantee also received TARP funds, this provision would not apply. Be reminded, that if ARRA funds are used support any NIH program that has a citizenship requirement (e.g., training and career programs); those programmatic requirements would also apply to the ARRA funding.
Are investigators from federal agencies eligible to apply for ARRA Awards?
In general, Federal institutions are eligible to apply for NIH grants, including research project grants. However, special policies apply to awards to Federal agencies. They are described at http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part13.htm

Federal institutions also must meet the eligibility requirements of the grant program from which support is sought. However, according to the NIH Grants Policy Statement, PHS organizational segments, other than IHS hospitals, may receive NIH grant support under exceptional circumstances only. NIH does not intend to classify ARRA funding as an "exceptional circumstance"; therefore, the standard rules would apply. CDC and FDA employees can collaborate, but would not be eligible for direct extramural grant funding from NIH.
Can my recently reviewed but unfunded investigator-initiated grant application be awarded with ARRA funds?
ICs do have some discretion to support previously reviewed investigator-initiated applications with their ARRA allocation. You should contact the program officer assigned to your application to discuss this possibility.
Can ARRA funds be used to award Career Development Awards?
Each NIH Institute is developing plans to use ARRA funds for previously reviewed and scientifically meritorious applications that meet the ARRA goals of job creation and retention and economic stimulus. Awards made with ARRA funds must, furthermore, be capable of making significant progress within the two year ARRA funding period. Many of the mentored career award programs are designed to sustain funding for longer than two years in order for the awardee to acquire the research skills necessary to become a competitive independent scientist. As such, each Institute will need to weigh the propriety of ARRA funds for mentored career awards on a case by case basis. Applicants who have recently had favorably reviewed Career Development applications that were not funded can contact their program officer to determine whether they may be considered for support under the ARRA.
Can a US company, owned by a foreign entity, receive ARRA stimulus funds?
The NIH Grants Policy Statement defines a domestic organization as “A public (including a State or other governmental agency) or private non-profit or for-profit organization that is located in the United States or its territories, is subject to U.S. laws, and assumes legal and financial accountability for awarded funds and for the performance of the grant-supported activities.” Pursuant to this policy, organizations owned by a foreign company are eligible for NIH’s ARRA programs if the applicant organization is located in the US and the work will be performed in the US by US citizens and/or foreign nationals.
Are foreign institutions eligible to apply for ARRA Grants?
No, applications from foreign institutions are not permitted. In keeping with the purposes of the Recovery Act (in particular, to preserve and create jobs and to promote economic recovery in the United States, as well as provide investments needed to increase economic efficiency by spurring technological advances in science and health), applicants must be domestic institutions or organizations in that they must be located in the 50 states, territories, and possessions of the United States, the Commonwealth of Puerto Rico, the Trust Territory of the Pacific Islands, or the District of Columbia.

Domestic applicants may include a foreign component if the funding for its foreign component does not exceed 10% of the total requested direct costs, or $25,000/year aggregate total for all foreign subcontracts and subawards, whichever is less.
Are foreign scientists working at domestic institutions eligible to be Principal Investigators, Key Personnel, and/or other personnel supported by an ARRA Grant?
Yes, foreign nationals working in the US are eligible to work and be compensated with ARRA provided they are employed by a domestic institution and are in the country under valid visas. It is the grantee institution’s responsibility to assure that an individual’s visas will allow them to remain in this country long enough for them to be productive on the research project. NIH does not provide guidance on or assess the different types of visas. Grantee organizations are expected to have consistently applied policies in place to address this area. There is a restriction in Section 1611 of ARRA that applies to institutions receiving Troubled Asset Relief Program (TARP) funds--primarily financial institutions. However, unless a NIH grantee also received TARP funds, this provision would not apply. Be reminded, that if ARRA funds are used support any NIH program that has a citizenship requirement (e.g., training and career programs); those programmatic requirements would also apply to the ARRA funding.

B. Considerations for New Investigators

Can New and Early Stage Investigators apply for grants made under the American Recovery and Reinvestment Act?
Yes. New and Early Stage Investigators are encouraged to apply for ARRA Challenge Grants (RFA-OD-09-003), ARRA Grand Opportunities Grants (RFA-OD-09-004). New investigators also may apply for other ARRA funding opportunities listed at http://grants.nih.gov/recovery/.
Can I retain my status as a New and Early Stage Investigator if I receive a grant made under the American Recovery and Reinvestment Act?
In most cases, no. Although the award period is usually limited to two years, most ARRA grants are substantial and award amounts often exceed those available for traditional NIH research grants (R01). Accordingly, New Investigators who receive a Challenge Grant or a Grand Opportunities Grant will lose their New Investigator status; Exception: if you receive an R21 or an R34 award under one of the Autism-related ARRA initiatives (RFA-MH-09-172, RFA-MH-09-173), you will retain your New Investigator status. Additional information about New and Early Stage Investigators is available at: http://grants1.nih.gov/grants/new_investigators/index.htm.
I’m a New Investigator. Will my application for an ARRA Challenge Grant or Grand Opportunities Grant receive special consideration at review and funding? (New: 04/07/2009)
Yes; however, the treatment may be different than for traditional research grants (R01). For example, applications submitted by New Investigators for Challenge Grants (RC1) or Grand Opportunities Grants (RC2) will not be clustered during peer review. Nonetheless, reviewers will consider the career stage of the Principal Investigator at the time of review. Similarly, NIH institutes and centers may accord special consideration to New and Early Stage Investigators at the time of award. Previously announced FY 2009 policies regarding New and Early Stage Investigators apply to R01 applications competing for appropriated funds (see http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-013.html)
I self-identified on my grant application as a New Investigator/Early Stage Investigator (ESI), but this designation does not appear when I view the grant folder in the NIH Commons. How can I correct the information? (New: 05/29/2009)
Only R01 applications will be noted by the eRA Commons as New Investigator/ESI eligible. Principal Investigators who are identified in the eRA Commons as eligible for New Investigator/ESI status, even if they ‘self-identified’ their eligibility on their application, will only see this designation in the eRA Common in association with R01 applications and not on NIH Challenge Grants, Grand Opportunities, AREA applications or other non-R01 activities.

C. Application Formatting Requirements

Does the 2-page limit and 10-publication limit on Biographical Sketches apply to a) all three sections of the Biographical Sketch; and b) all Key Personnel or just the Principal Investigator?
Yes, the 2 page limit includes all three sections of the Biographical Sketch (A: Positions and Honors, B: Selected peer-reviewed publications or manuscripts in the press, and C: Research Support), and the number of publications cited in the PD/PI’s biographical sketch is limited to ten or fewer items. The exception is the Academic Research Enhancement Award (R15) RFA-OD-09-007, which does not have the two-page limit. PD/PIs should cite their most relevant publications and those that highlight the significance of past accomplishments. These limits apply to biographical sketches for all key personnel as well as the PD/PI.

As a reminder, “other support” is not a required element of the Biographical Sketch. “Other support” information will be required for applicants selected to receive grant awards using established Just-in-Time procedures.
For grants that have been renegotiated to a two-year ARRA-supported project period, the Institutes and Centers must obtain from applicants modified specific aims, etc. for uploading to e-Additions. What are the format requirements for this document? (Updated: 05/08/2009)
The modified project description is necessary to ensure that the reporting for the revised project is an accurate depiction of the research that was awarded, and to ensure that the electronic grants folder contains an accurate project description for future use in CSR, etc. Depending upon the extent to which the renegotiated project is changed, it is necessary to obtain the following revised sections, labeled with headers EXACTLY as shown:

· Modified Project Summary/Abstract
· Modified Specific Aims Section
· Modified Public Health Relevance Section

PDF format is preferred to MS Word or text, although eAdditions can accept any of these formats.

D. Review Processes

What review criteria and scoring system will be used for the ARRA Funding opportunities?
The new, 9-point scoring system, including criterion scoring where applicable, will be used for all ARRA programs.

For Challenge Grants and other research project grants, the enhanced review criteria (http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-054.html) will be used. For ARRA applications for non-research project grants, such as construction and instrumentation grants, the review criteria listed in the active FOA will be used.

For ARRA Competitive Revisions, the standard review criteria for the grants activity (i.e., R01, R21, R03, U01, P20, P50, T32, S10, etc.) will be used. No special review criteria that were applied to the announcement for which the original parent application was submitted will be considered. However, the application will be considered in the context of the parent grant. The committee will consider the scientific merit of the new work proposed and the appropriateness of the proposed expansion of the scope of the parent project. Note that the enhanced review criteria (NOT-OD-09-025: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-058.html) are standard now for research grant applications and cooperative agreements.

Administrative supplement applications, including Summer Research Supplements, are not peer-reviewed. Each of NIH’s Institutes and Centers has an established process for reviewing administrative supplements.
Many of the ARRA awards will be made in September of 2009. Will there be a problem with obtaining just-in-time approvals for IACUC and IRB for so many research projects at one time, in addition to the awards that will be made with appropriated funds?

IACUC: By the time Challenge Grants and other new programs have been peer-reviewed and approved by council, the awards will be made during the restricted award period for FY09. During this time period (usually the last quarter of the FY), OLAW allows ICs to issue restricted awards with terms and conditions that allow the institution to begin other work on the grant. Animal research is not allowed until IACUC approval is obtained. There is an interim restricted code for vertebrate animals (code 48). The institution has until November 30 to provide verification of IACUC approval. Please note that the PHS Policy on animal research provides less flexibility than the DHHS human subjects protection regulations. OLAW is anticipating an increase in requests for restricted awards and is planning temporary staffing increases to accommodate the volume. We will be announcing guidance on the restricted award process later this summer

IRB: For grants with Acceptable human subjects (code 30), IC’s can make restricted awards without intervention from OER. Unlike OLAW, there is no required code change, but we advise the IC to issue an award with restrictions so that no human subjects related activities can take place until the Assurance and IRB approval have been obtained by the IC. We have suggested language for these restricted awards on our web: site: http://odoerdb2.od.nih.gov/oer/committees/hsp/hsp_memo_20010208.htm

For grants where the SRG found human subjects concerns (code 44), or found the inclusions to be “unacceptable”, we can issue an interim code of 48 to allow the IC to issue a restricted award. We will do that now if the IC so requests and once we get nearer to the end of the fiscal year (~ July), we automatically do this and notify the IC’s. No human subjects related activities can take place until the human subjects concerns have been resolved, the assurance number is provided and IRB approval has been obtained.

E. ARRA Award Dates and Project Period Timelines

When will ARRA award decisions be made?

When will ARRA decisions and awards be made for NIH Challenge Grants and competitive revisions?
For NIH Challenge Grants and competitive revision (formerly known as competitive supplement) applications made in response to NOT-OD-09-058, funding decisions and awards will be issued on or prior to September 30, 2009 for applications submitted in response to this notice, and on or prior to September 30, 2010 for applications submitted in response to any reissuance of this notice. The anticipated start date for Challenge Grants is 9/30/2009.

When will ARRA decisions and awards be made for administrative supplements?
For administrative supplements announced in NOT-OD-09-056 and NOT-OD-09-060, each participating Institution and Center (IC) has established a timeline for reviewing and awarding supplements, and these are explained on their web sites. The earliest awards will be made in spring 2009. The URLs for these IC web sites are compiled at: http://grants.nih.gov/recovery/ic_supp.html.

When will ARRA decisions and awards be made for renegotiated investigator-intiated activities?
For renegotiated grant awards made from applications previously peer-reviewed and eligible for funding, awards can be made as early as spring, 2009.

When will ARRA decisions and awards be made for mechanisms sponsored by a single or only a few institutes?
For other ARRA activities, please refer to the NIH Guide Notice or Funding Opportunity Announcement. A complete list of ARRA award opportunities is compiled at: http://grants.nih.gov/recovery/
When must ARRA projects be completed?
All ARRA funds must be obligated by NIH no later than September 30, 2010. In general this will mean ARRA project period end dates will be no later than September 29, 2011. However, all ARRA awards are subject to the standard terms of award as indicated in the NIH Grants Policy Statement, including the authority to extend the final budget period of a previously approved project period for up to 12 months without additional funds.
Are no-cost extensions permissible for Challenge Grants?
The proposed award period in the Challenge Grant application will end on or before 9/29/2011. There are no specific constraints on no-cost extensions for the Challenge award program. All ARRA awards are subject to the standard terms of award as indicated in the NIH Grants Policy Statement including the authority to extend the final budget period of a previously approved project period for up to 12 months without additional funds. See http://grants.nih.gov/grants/policy/nihgps_2003/index.htm

F. Recovery Act Terms of Award

Are there special reporting requirements for NIH’s ARRA programs?
Yes. In addition to the NIH General Terms of Award (http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_part4.htm), there are special reporting requirements for recipients of ARRA funds (http://grants.nih.gov/grants/policy/NIH_HHS_ARRA_Award_Terms.pdf) (PDF - 40 KB). The ARRA reporting requirements must be met on a quarterly basis. The mechanism for submitting these reports is still under development. Details on the information that must be reported are provided in Section V of each of NIH’s ARRA Funding Opportunity Announcements (FOAs).
Is there a limit on the cost of equipment that can be requested in Administrative Supplement, Competitive Revision, and/or NIH Challenge Grant applications? (New: 04/17/2009)
NIH defines equipment as an item of property that has an acquisition cost of $5,000 or more (unless the organization has established lower levels) and an expected service life of more than one year. NCRR’s shared instrumentation programs could be exploited requests for single items costing over $100,000 (each); however, the FY2009 receipt date for this program has passed. Requests for multiple items of equipment with an aggregate cost that exceeds $100,000 are permitted as part of an Administrative Supplement, Competitive Revision or NIH Challenge Grant application. Equipment requests made in the context of an Administrative Supplement, Competitive Revision or NIH Challenge Grant application should be well-justified in the context of the proposed research.
How much of an ARRA grant can be designated for support of a foreign entity? (New: 04/17/2009)
Annual funding for any foreign component should not exceed 10% of the total requested direct costs or $25,000 (aggregate total for all subcontracts and subawards), whichever is less.
Can ARRA grant budgets include direct costs to address ARRA administrative and reporting requirements? (New: 05/15/2009)
No. It has been determined that ARRA requirements do not provide sufficient justification to support the provision of direct costs for administrative support in addition to the Facilities and Administrative (F&A) costs in the awarded budget.

NIH staff will continue to evaluate direct costs requested for administrate support using the guidance provided in OMB Circular A-21 F.6.b.(2) http://www.whitehouse.gov/omb/circulars/a021/a021.html. However, ARRA requirements will not be considered in this determination, because they are incorporated within the core administrative support for the project, which is reimbursed to the institution through the provision of F&A costs.

When direct costs have been requested to address ARRA administrative and reporting requirements in requested budgets, NIH staff will make appropriate adjustments . Revised budgets submitted solely to remove administrative costs will not be accepted.
Academic institutions with a modified total direct cost F&A base are generally entitled to F&A costs on the first $25 thousand of each sub-grant or subcontract. If a subcontract is modified due to the receipt by the primary grantee of an ARRA competitive supplement, is the grantee entitled to F&A on the 1st 25K of the revised subcontract? (New: 06/12/2009)
A modified subcontract does not necessarily entitle the recipient to apply its F&A rate to an additional 25K of the subcontract, and NIH does not accept revised budgets subsequent to an award. If the grantee believes that the modifications represent a major renegotiation of the subcontract such that additional F&A would be justified, the grantee may submit a detailed explanation to the Grants Management Officer and request that the F&A base include an additional 25K for the renegotiated subcontract. Such a request must be fully documented and approval of the request is at the discretion of the awarding IC and subject to the availability of funds. Grantees are reminded of their flexibility to rebudget from direct costs to F&A to cover administrative costs.
Do the Standard ARRA Terms and Conditions for Division A Funds, dated March 2, 2009, or subsequent versions, apply (i.e., flow-down) to subrecipients? (New: 06/12/2009)
Grantees must impose the ARRA Terms and Conditions upon subrecipients, and must separately identify for each subrecipient, and document at the time of subaward and at the time of disbursement of funds, the Federal award number, any special CFDA number assigned for ARRA purposes, and amount of ARRA funds. In order for the grantee to meet its quarterly reporting obligation to the federal government, it must require subrecipients to account for, track, and report to the grantee on ARRA funding in such a way that distinguishes the funding from non-ARRA funds. For purposes of reporting to the federal government, the recipient must submit detailed information on sub-awards to include the data elements required required to compy with the Federal Funding Accountability and Transparency Act of 2006 (Public Law 109-282). Those requirements are that for any subaward equal to or larger than 25K, the following information must be reported:

· The name of the entity receiving the sub-award;
· The amount of the sub-award;
· The transaction type;
· The North American Industry Classification System code or Catalog of Federal Domestic Assistance (CFDA) number;
· Program source;
· An award title descriptive of the purpose of each funding action;
· The location of the entity receiving the award;
· The primary location of performance under the award, including the city, State, congressional district, and country; and
· A unique identifier of the entity receiving the award and of the parent entity of the recipient, should the entity be owned by another entity.

Subawards less than 25K or to individuals may be reported in the aggregate. The definition of terms and data elements and specific instructions for reporting including required formats, will be provided in subsequent guidance issued by HHS.
Can an ARRA-funded grant be transferred to a new institution if the PI moves? (New: 06/24/2009)
NIH Policy supports such a transfer; however, because of the requirement by the HHS Payment Management System to have a unique Document Number schema for ARRA awards, NIH is not able to use established business processes to accommodate such a transfer. While we can transfer an application before an ARRA award is issued, options currently available to transfer awarded ARRA grants are quite limited. PD/PIs should be forthcoming in advising NIH IC staff of the possibility of upcoming transfers when contacted about possible funding of an application with ARRA dollars so that options can be discussed before an ARRA award is issued. NIH is developing a new business process to accommodate these transfers; however, at this time we do not know how long a solution might take to implement.
What are the reporting requirements for the Federal Cash Transactions Report (SF 272) when grantees have both non-ARRA & ARRA awarded funds? (New: 07/31/2009)
Since ARRA funds are posted in a "P" account and non-ARRA funds are posted in a "G" account, separate Federal Cash Transactions Reports (SF 272) will be required for both (P and G); a single consolidated 272 for ARRA & non-ARRA funds is not an option. Grantees may access the SF 272 report at the PIN level using the same password as before. Once logged into the Division of Payment Management (DPM) Electronic 272 System, grantees may access all of the Payment Management System (PMS) Payee Accounts assigned to that PIN, and are required to complete a separate SF 272 report for each PMS Payee Account. Grantees may direct additional questions to the PMS Account Representative found on previous SF 272 reports. New grantees may direct questions to the PMS Help Desk via phone (877) 614-5533 or E-Mail PMSSupport@psc.gov.
An ARRA-funded supplement has been made to a parent grant that is funded with non-ARRA funds. Are separate Federal Cash Transactions Reports (SF 272s) required for the parent and the ARRA-funded supplement? (New: 07/31/2009)
Yes.
An ARRA-funded supplement has been made to a parent grant that is funded with non-ARRA funds. The ARRA supplement will end several years before the parent. Do we need to separately closeout the ARRA-supplement at the time it ends? (New: 07/31/2009)
Yes. As noted in the ARRA-specific term for all ARRA supplements and competing revisions, separate closeout documents (Final Progress Report, Final Financial Status Report and Final Inventions Statement) will be required to close out the ARRA funding even when the parent grant continues.

G. Stem Cell Policy Guidance

How can I submit a competing application for ARRA or other NIH initiatives proposing the use of human embryonic stem cells (hESC), pending the issuance of NIH Guidelines for hESC? (New: 04/21/2009)
In accord with the NIH Guidance issued April 17, 2009 (NOT-OD-09-085), NIH will accept competing applications for research proposing to use hESC during the period of the development of the NIH Guidelines for hESC. The review and funding of these applications will be deferred until NIH issues final Guidelines.

Such applications should identify illustrative cells for the purposes of the research plan. The yes/no hESC stem cell checkboxes should be checked appropriately (this is item 4 on the PHS 398 cover page supplement for electronic submissions using the SF 424 (R&R); for paper submissions this is at the end of PHS 398 Form Page 2). Additionally, applicants should indicate in the appropriate checkbox that the specific stem cell line to be used cannot be referenced at this time. As indicated in the Notice, once the Guidelines have been issued in final applicants will have the opportunity to revise their application as necessary to comply with the Guidelines, including utilization of eligible cells. The modified applications will then be peer reviewed and considered for funding.
How will NIH consider ARRA administrative supplement requests, pending the issuance of NIH Guidelines for human embryonic stem cells (hESC)? (New: 04/21/2009)
As stated in NIH Guide Notice NOT-OD-09-085, NIH will not consider requests for administrative supplements to any grants that include costs for, or involve the study of, hESCs until the Guidelines are finalized.

II. NIH Challenge Grants

A. General Questions

Where can I find more information on the NIH Challenge Grants?
For detailed information about Challenge Grants, please refer to the website http://grants.nih.gov/grants/funding/challenge_award/.

From here you may also access Institutes and Centers websites detailing their specific Challenge award interests. http://grants.nih.gov/grants/funding/challenge_award/IC_ChallengeWebPage.htm

The Funding Opportunity Announcement (FOA) is posted at http://grants.nih.gov/grants/guide/rfa-files/RFA-OD-09-003.html
Are the Challenge Awards limited in scope to specific scientific topics?
The NIH has identified a range of Challenge Areas that focus on specific knowledge gaps, scientific opportunities, new technologies, data generation, or research methods that would benefit from an influx of funds to quickly advance the area in significant ways. Within each broad Challenge Area the NIH Institutes, Centers, and Offices have specified particular Challenge topics that address their missions. These broad Challenge Areas are provided below.

(01) Behavior, Behavioral Change and Prevention
(02) Bioethics
(03) Biomarker Discovery and Validation
(04) Clinical Research
(05) Comparative Effectiveness Research
(06) Enabling Technologies
(07) Enhancing Clinical Trials
(08) Genomics
(09) Health Disparities
(10) Information Technology for Processing Health Care Data
(11) Regenerative Medicine
(12) Science, Technology, Engineering and Mathematics Education
(13) Smart Biomaterials – Theranostics
(14) Stem Cells
(15) Translational Science

A detailed description of the specific Challenge topics within each area that have been accorded the highest priority by the NIH Institute, Center, or Office indicated can be accessed in a single Omnibus at http://grants.nih.gov/grants/funding/challenge_award/Omnibus.pdf (PDF - 1.67 MB)
Where can I get advice on choosing a Challenge topic?
Applicants are encouraged to consult with an NIH program officer for assistance in choosing the Challenge topic that best fits their research program. Each of the NIH Institutes and Centers has developed a website to explain their Challenge Grant program and provide access to staff members who can help you. Those websites are compiled at: http://grants.nih.gov/grants/funding/challenge_award/IC_ChallengeWebPage.htm
How were the Challenge Topics chosen?
Topics were chosen through extensive discussion among members of the scientific leadership of NIH. Many of the topics reflect issues identified in the strategic plans developed by each NIH Institute and programmatic office, bearing in mind that ARRA funding would be available only for two years. NIH Institute and Center plans are generally developed with public input, including the National Advisory Councils of the NIH Institutes and Centers, and in some cases, the US Congress.
Can an NIH Challenge Grant application from a domestic institution include a foreign component?
Yes, domestic institutions and organizations (i.e. those located in the 50 states, territories and possessions of the United States, Commonwealth of Puerto Rico, Trust Territory of the Pacific Islands, or District of Columbia) may include a foreign component if the funding for its foreign component does not exceed 10% of the total requested direct costs, or $25,000 aggregate total per year for all foreign subcontracts and subawards, whichever is less.
Does the Challenge Grant budget limit of $500K per year include indirect costs?
Yes. Challenge Grants are limited to $500K in total (direct and indirect, including consortium/contractual) costs per year for no more than two years.
Where will NIH Challenge Grants be reviewed: in standing study sections or Special Emphasis Panels?
Because American Recovery and Reinvestment Act opportunities will be issued as Requests for Applications, the applications will be reviewed in Special Emphasis Panels, not the standing study sections.

B. Applying for a Challenge Grant Award

Where can I find the Challenge Award application forms, and which forms are required?
Challenge grant applications must be submitted electronically through Grants.gov on the SF 424 (R&R) forms. The Challenge Grant application may be accessed through the Funding Opportunity Announcement (FOA), located at http://grants.nih.gov/grants/guide/rfa-files/RFA-OD-09-003.html, or directly from Grants.gov.
What form components are required for the Challenge Award applications?

• SF424 (R&R) (Cover component)
• Research & Related Project/ Performance Site Locations
• Research & Related Other Project Information
• Research & Related Senior/ Key Person
• PHS398 Cover Page Supplement
• PHS398 Research Plan
• PHS398 Checklist
• Research & Related Budget

Optional Components:
• PHS398 Cover Letter File
• Research & Related Subaward Budget Attachment(s) Form
Does the 2-page limit and 10-publication limit on Biographical Sketches apply to a) all three sections of the Biographical Sketch; and b) all Key Personnel or just the Principal Investigator?
Yes, the 2 page limit includes all three sections of the Biographical Sketch (A: Positions and Honors, B: Selected peer-reviewed publications or manuscripts in the press, and C: Research Support), and the number of publications cited in the PD/PI’s biographical sketch is limited to ten or fewer items. PD/PIs should cite their most relevant publications and those that highlight the significance of past accomplishments.

As a reminder, “other support” is not a required element of the Biographical Sketch. “Other support” information will be required for applicants selected to receive grant awards using established Just-in-Time procedures.
Can equipment requests be included in the budget for NIH Challenge Grant applications?
Yes. Equipment requests should be made in Section C of the SF424 Research and Related Budget form. Instructions for completing the budget form are provided beginning on page I-69 of the SF424 Application Guide, located at http://grants.nih.gov/grants/funding/424/index.htm.
Can I submit an application I’ve already submitted to another IC and for which I am currently awaiting response?
The NIH will not accept any application in response to the Challenge Grant funding opportunity that is essentially the same as one currently pending initial review unless the applicant withdraws the pending application. Scientifically distinct applications are required. In addition, should an investigator want to submit a previously unfunded application (that is no longer being considered for payment) in response to the NIH Challenge Grant program, the application should be prepared as a NEW application. That is, the application for the NIH Challenge Grant program must not include an “Introduction” describing the changes and improvements made, and the text must not be marked to indicate the changes from the previous unfunded version of the application. You may want to contact the program officer for your existing application and discuss topics you could pursue for the NIH Challenge Grant program.
Is preliminary data required? Where in the research plan should preliminary data be included?
Preliminary data is not required, but it is allowed. It should be included as part of the approach section.

Can applications to the Challenge Grant RFA be resubmitted?
The Challenge Grant FOA states that because this is a one-time-only solicitation, resubmissions are not permitted. However, per the application guide, unfunded applications to RFAs may be resubmitted as new applications to another FOA. See notice announcing this practice at http://grants.nih.gov/grants/guide/notice-files/NOT-OD-03-019.html.

The reference cited/bibliography section is limited to 1 page. It is permissible to abbreviate any aspect of the citations? (New: 04/21/2009)
The author list may be shortened to the first author, followed by “et al.”. All other aspects of the standard format specified in the SF424 instructions are applicable. The SF424 application guide (http://grants.nih.gov/grants/funding/424/index.htm#), page I-58, contains instructions for preparing the bibliography.

C. Investigator Eligibility

Can investigators and institutions submit more than one NIH Challenge Grant application?
There is no limitation on the number of grant applications that may be submitted from an applicant institution. The same Principal Investigator may be listed on multiple applications, provided that each application is scientifically distinct.
If a New Investigator or Early Stage Investigator is awarded an NIH Challenge Grant, will he or she retain status as New or Early Stage Investigator?
In most cases, no. Although the award period is usually limited to two years, most ARRA grants are substantial and award amounts often exceed those available for traditional NIH research grants (R01). Accordingly, New Investigators who receive a Challenge Grant or a Grand Opportunities Grant will lose their New Investigator status. Exception: if you receive a R21 or a R34 award under one of the Autism-related ARRA initiatives (RFA-MH-09-172, RFA-MH-09-173), you will retain your New Investigator status. Additional information about New and Early Stage Investigators is available at: http://grants1.nih.gov/grants/new_investigators/index.htm.
Will being awarded an NIH Challenge Grant affect eligibility for a Mentored Research Career Award (mentored K)?
Yes. The NIH Challenge Grants are substantial competing NIH research grants. NIH Challenge Grant recipients will not be considered New PIs or Early Stage Investigators when they apply for NIH grants in the future. In most cases, receipt of a Challenge Grant will affect eligibility for a mentored career award, such as a K08 or K23. Exception: Receipt of a Challenge Grant will not affect future eligibility for the limited number of mentored career awards intended to provide established or mid-career investigators with opportunities to train in a new field, such as some types of K01s and K18s. You are encouraged to work closely with a program officer in preparing your application(s) and to consider the types of awards best suited for your stage of career development.
Can a mentored K-award recipient apply for an NIH Challenge Grant?
Yes. Mentored K-award recipients are encouraged to obtain funding from NIH or other Federal sources, either as a PI on a competing research grant award or cooperative agreement, or as project leader on a competing multi-project award. However, such funding is typically obtained AFTER the K-award is made. Also, there are salary restrictions, as explained in the guide notice located at http://grants.nih.gov/grants/guide/notice-files/NOT-OD-08-065.html.

We strongly recommend that you work closely with a program officer in preparing your application(s) to ensure they do not overlap in a way that would cause either of them to be ineligible for award.
Are foreign institutions eligible to apply for NIH Challenge Grants?
No, applications from foreign institutions are not permitted. In keeping with the purposes of the Recovery Act (in particular, to preserve and create jobs and to promote economic recovery in the United States, as well as provide investments needed to increase economic efficiency by spurring technological advances in science and health), applicants must be domestic institutions or organizations in that they must be located in the 50 states, territories, and possessions of the United States, the Commonwealth of Puerto Rico, the Trust Territory of the Pacific Islands, or the District of Columbia.

Domestic applicants may include a foreign component if the funding for its foreign component does not exceed 10% of the total requested direct costs, or $25,000/year aggregate total for all foreign subcontracts and subawards, whichever is less.
Are foreign scientists working at domestic institutions eligible to be Principal Investigators, Key Personnel, and/or other personnel supported by an NIH Challenge Grant?
Yes, foreign nationals working in the US are eligible to work and be compensated with ARRA provided they are employed by a domestic institution and are in the country under valid visas. It is the grantee institution’s responsibility to assure that an individual’s visas will allow them to remain in this country long enough for them to be productive on the research project. NIH does not provide guidance on or assess the different types of visas. Grantee organizations are expected to have consistently applied policies in place to address this area.

There is a restriction in Section 1611 of ARRA that applies to institutions receiving Troubled Asset Relief Program (TARP) funds--primarily financial institutions. However, unless a NIH grantee also received TARP funds, this provision would not apply. Be reminded, that if ARRA funds are used support any NIH program that has a citizenship requirement (e.g., training and career programs); those programmatic requirements would also apply to the ARRA funding.
Are investigators from federal agencies eligible to apply for Challenge Grants?
In general, Federal institutions are eligible to apply for NIH grants, including research project grants. However, special policies apply to awards to Federal agencies. They are described at http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part13.htm.

Federal institutions also must meet the eligibility requirements of the grant program from which support is sought. However, according to the NIH Grants Policy Statement, PHS organizational segments, other than IHS hospitals, may receive NIH grant support under exceptional circumstances only. NIH does not intend to classify ARRA funding as an "exceptional circumstance"; therefore, the standard rules would apply. CDC and FDA employees can collaborate, but would not be eligible for direct extramural grant funding from NIH.

D. Reporting Requirements

How will the funds awarded from NIH’s ARRA program be tracked?
New and distinct Catalog of Federal Domestic Assistance (CFDA) numbers have been created to correspond with and track all awards issued under ARRA. The public can track all ARRA funds through the central Recovery.gov Web site.

E. Challenge Grant Review and Award (New: 07/29/2009)

ARRA provided NIH the ability to create the Challenge Grant, a funding opportunity that would support research on topic areas which address specific scientific and health research challenges that would benefit from a significant 2-year jumpstart of funds. The Challenge Grant program was designed as a onetime only request for applications. NIH received an unprecedented response from the scientific community, making funding for this opportunity extremely competitive. Due to the uniqueness of the Challenge Grants, percentiles for these applications cannot be compared to percentiles from previous review rounds of other grant mechanisms.

My application was Not Discussed. What does that mean?
For Stage 1 of the review process, Challenge Grant applications were sent to reviewers by mail. These reviewers provided criterion scores and written critiques of the specific science.

For Stage 2 of the peer review process, a panel of reviewers provided preliminary impact scores that determined the order of review for discussion. Stage 2 reviewers then met in face-to-face panel discussions and provided final overall impact scores. These impact scores form the basis upon which percentiles were calculated.

The review panels discussed applications with the highest preliminary impact scores. Applications that were not discussed will receive criterion scores and critiques, but will not receive numerical overall impact/priority scores. During the Stage 2 meeting, all reviewers could request that any application be discussed, regardless of preliminary scores.
My application received a score. How do I interpret my score/percentile?
NIH converts the overall impact/priority score into a percentile. A typical percentile provides a historical ranking of an application relative to the other applications reviewed by the same study section across all types of grant programs. Percentiles are distributed along a 100 percentile range.

Because of the one-time nature of the Challenge Grant program, percentiles were assigned using final overall impact/priority scores against other Challenge Grant applications within each individual study section meeting.

Decisions on final overall impact/priority scores were made by a panel of scientists with broad expertise across a range of disciplines.
My scores and percentiles seem low but I am not funded. Yet colleagues with the same scores or percentiles received funding. Why?
Score is only one factor that NIH Institutes and Centers (ICs) use to make funding decisions. In addition to the scientific merit of the proposed project as determined by peer review, NIH also considers availability of funds and relevance of the proposed project to program priorities.
When can I expect an award decision?
Most award decisions for Challenge Grants will be made by September 30, 2009. The exception is for Challenge Grant applications involving human embryonic stem cells. Those applications will be reviewed in fall of 2009 and awarded in spring of 2010.
When will summary statements be made available?
Summary statements for the Challenge Grant applications should all be available by August 3, 2009.
With so many applications submitted for the Challenge (RC1) initiative, how did NIH find enough reviewers?
The large number of Challenge applications received is approximately equal to the total number of applications that NIH receives in one of three major review round each year. This unprecedented response to a call for applications on the part of the scientific community and its unprecedented response to a call for reviewers are powerful testimony to the strength of the NIH peer review system, the willingness of our extramural colleagues to support it through reviewer service, and the ability of our NIH staff to sustain such an increase in workload while maintaining the core values and integrity of NIH peer review.

It is important to note that this unprecedented achievement not only accommodated the largest number of applications that the agency has received in response to any funding opportunity or in any single funding cycle but also met a compressed deadline for finishing the reviews. NIH was able to achieve efficiency and ensure quality and timeliness by using a shorter grant application for Challenge grants – the bulk of ARRA applications – and a large cadre of mail reviewers.

To manage the breadth of topics expected in each Challenge study section and to accommodate the time constraints for completing review so that awards can be made by the end of September 2009, Challenge applications were reviewed using over 15,000 mail reviewers in specialized fields. These technical experts were asked to review each application, provide criterion scores, and to submit their critiques online.

The study sections reviewing Challenge applications were composed of experienced and highly regarded scientists who provided broad expertise and perspective across a range of scientific disciplines. These reviewers made the final assessments of overall impact and scored the applications after having reviewed and discussed the applications and technical assessments of the mail reviewers.
How were conflicts of interest managed for the Challenge reviews?
Given the volume of applications received and the compressed timeline for finishing the reviews, the NIH determined that it was necessary to recruit over 15,000 outstanding scientists to serve as mail reviewers (including some who would also be applicants). However, a Challenge applicant could only serve in the Challenge reviews as a mail reviewer and not as a study section member, and only for a study section(s) other than the one reviewing his/her application. Mail reviewers do not participate in the discussion or final scoring of the applications, and do not interact with other study section members.

III. ARRA Administrative Supplement and Competitive Revision FAQs

A. General Questions

For what activities (grant mechanisms) may competitive revisions be submitted?
Some Institutes and Centers (ICs) have placed restrictions on the activities they will consider for ARRA supplements. Please refer to http://grants.nih.gov/recovery/ic_supp.html to determine whether there are restrictions in the IC that sponsors the parent award. Fellowships (F series), individual career awards (most of the K series), and conference grants (R13/U13) are ineligible across all NIH ICs.
What can I do to minimize the potential for errors in the submission process for a competitive revision?
First, include an introduction with your application. After correctly identifying the application as a revision on the checklist, be sure that the checklist also identifies correctly the number of the parent grant. Follow the budget format (modular or full budget of the parent grant), and make sure that the time period of the competitive revision does not exceed two years and does not exceed (even by one day) the award period remaining on the parent grant. Also ensure that the PD/PI for the competitive revision is the same as the PD/PI for the parent grant (in the case of multiple PIs, this must be the contact PI.) Exception: If the budget for the parent grant was modular, but the requested budget for the competitive revision exceeds 250K in direct costs, a detailed budget is required. Grants.gov will generate a warning message upon submission, which can be ignored.
Will the ARRA administrative supplements and competitive revisions have the same serial number as the parent grant that was funded with NIH-appropriated funds? How will the separate ARRA tracking be accomplished?
Supplements and revisions will have the same Activity-IC-serial number as the parent grant. However, they will have a number of unique features associated with all ARRA awards. These include a special ARRA award banner, special ARRA award terms, ARRA-specific CFDAs, and unique document number. Additional details will be provided to the grantee community in a Guide Notice.
If my Phase I SBIR award is no longer active but is still eligible for a Phase II application, can I apply for a competitive revision or administrative supplement?
All awards, including SBIR/STTR activities, must be active at the time of application for the revision or supplement. If a Phase I SBIR/STTR award is no longer active, it is not eligible for a supplement or revision, even if it is still eligible for Phase II.
Can an intern be paid a stipend instead of a salary with an ARRA competitive revision or administrative supplement?
If the individual is supported from a research grant, that individual is supported as an employee; thus, the compensation is salary. NIH pays stipends only on training programs, such as the T32 and fellowships.
Can both administrative supplements and competitive revisions be requested under a single award? (Updated: 04/09/2009)
Yes. Requests for administrative supplements and competitive revisions (NOT-OD-09-058) can be submitted separately for the same grant. However, only one competitive revision application per grant should be submitted.
Can an administrative supplement or competitive revision request be submitted for only one piece of the collaborative program?
You are encouraged to consult with your program officer to determine if they will allow administrative supplements and/or competitive revisions to a collaborative set of grant awards.
Must all projects have at least 12 months remaining to be eligible to apply for either an administrative supplement or a competitive revision?
No. There is no minimum time required; however, the Notices for Competitive Revisions and Administrative Supplements both indicate “the parent grant must be active” and that the research proposed must be accomplished within the current competitive segment. This can include any no-cost extension already in place at the time the application is submitted; however grantees should be aware of the time remaining when preparing either Administrative Supplement or Competitive Revision requests. In some cases it might not be an appropriate request if only a few months remain.
If the indirect cost rate at my institution has changed since the parent grant was awarded, what indirect costs rate should I use for the administrative supplement or competitive revision application? (New: 04/09/2009)
NIH will use the rate in effect at the time the supplemental funds are committed. In other words, please include indirect costs in your requested budget at the current rate agreement.

B. Administrative Supplements (including Summer Research Experiences)

What should be included in the five-page proposal?
The proposal describing the project (which may not exceed five pages), should include:
a) Scope of the overall project and the anticipated contribution of the requested supplement; and
b) A discussion of how the supplement will accelerate the tempo of scientific research and/or allow for job creation and retention. In order to ensure that all expenditures in support of an administrative supplement advance the objectives of the Recovery Act, all applications must address Recovery Act justifications, including how the supplement is expected to stimulate the economy by:
            1) Enabling hiring of additional staff;
            2) Enabling increased hours of current part-time staff;
            3) Procuring additional needed equipment (costing under $100,000); and/or
            4) Recruiting for additional needed skills.

Is there a limit on the number of administrative supplements that can be requested under a single award?
Some ICs have placed restrictions on the number and type of supplement requests they will accept. Please consult the IC web site(s), which are compiled at http://grants.nih.gov/recovery/ic_supp.html to determine the specific terms in place in the IC that supports the parent grant. Each request must be appropriately justified. If there are plans to submit multiple administrative supplement (NOT-OD-09-056) requests for the same grant, you are encouraged to submit them as a single, combined request. EXCEPTION: Requests for summer research must be submitted separately (NOT-OD-09-060) from requests for administrative supplement (NOT-OD-09-056) support on the same grant. Plans to apply for multiple administrative supplements for awards from different ICs should be disclosed in the requests.

Where and in what format should administrative supplement requests be submitted?
The Institutes and Centers (ICs) receive their own applications for administrative and summer research supplements. Each IC has its own receipt dates and eligibility criteria. The IC web sites explaining these criteria are compiled at: http://grants.nih.gov/recovery/ic_supp.html.

The supplement requests should be submitted on the paper form PHS 398. Instructions for submitting an administrative supplement request are contained in the Notices. The Notices are located at: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-056.html for administrative supplements, and http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-060.html for summer research supplements.

Are recruitment fees to third parties allowable for summer internships?
Recruitment costs are subject to the conditions and restrictions contained in the applicable cost principles. These costs may include help-wanted advertising costs, costs of travel by applicants to and from pre-employment interviews, and travel costs of employees while engaged in recruiting personnel. Project funds may not be used for a prospective trainee’s travel costs to or from the grantee organization for the purpose of recruitment. However, other costs incurred in connection with recruitment under training programs, such as advertising, may be allocated to a grant-supported project according to the provisions of the applicable cost principles (also see “Travel” and “Relocation Costs” in the selected Items of Costs section of the NIH Grants Policy Statement: http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part6.htm#_Toc54600125.

Are there ARRA opportunities to support hiring laboratory staff members during the regular school year, or only during the summer months? (New: 04/07/2009)
YES; ARRA Administrative Supplements can include support for research staff including pre-doctoral students, postdoctoral students (including extending support for senior postdocs), postbaccalaureate students (recent college and master’s degree graduates), medical students in “off years” (e.g., medical, dental, veterinary, clinical psychology, nursing students) seeking extended time off for research experience, or on shorter term breaks.

Additionally, NIH is prepared to make awards with Recovery Act funding under other existing programs that provide administrative supplements (such as PA-08-190; Research Supplements to Promote Diversity in Health-Related Research, and PA-08-091; Research Supplements to Promote Re-Entry into Biomedical and Behavioral Research Careers). See those specific notices for more information.
Are high school and college graduates eligible for the ARRA-funded Summer Opportunities for Students and Educators Program? (New: 04/22/2009)
Yes, both high school and college graduates are eligible.
Is there a web site where students and science educators can visit to see if there are summer job opportunities in theARRA-funded Summer Opportunities for Students and Educators Program in their geographic region? (New: 04/22/2009)
When funding decisions are made in early May, we will provide information on participating scientists, the types of positions available, and the area of science involved at http://grants.nih.gov/recovery/summer_opps.html. The site will also indicate when these positions are filled.
I received an administrative supplement to support students over the summer and specified in my application a budget end date in August. But the award notice reflects an budget/project period end date of 10/31/2009 (or later). Should I notify the awarding Institute or take other action to correct this? (New: 05/15/2009)
No, this is not an error. The end date is set for a date on or later than 10/31/2009 to accommodate additional time needed to modify eRA Commons systems for Project Extensions, eFSR and Closeout so that these can accommodate separate reporting requirements for ARRA Supplements/Revisions (also known as Type-3) awards. No action is needed on the part of the awardee. In the event you receive a Recovery Act Type 3 award with a budget/project period end date that is before 10/31/2009, be aware that the eRA Commons features will not be immediately available for your use.
I received an ARRA-funded administrative supplement for research to be conducted this summer and next summer. The supplement lasts for 18 months so it can include work in the summer quarters, but during the non-summer quarters no work will occur under the supplement and no costs will be incurred. Do I still have to provide quarterly reports (as required by ARRA) even when no work is expected during those non-summer quarters? (New: 05/15/2009)
Yes. The requirement to provide quarterly progress reports applies for the life of the Recovery Act award, whether or not any activity occurred under the grant in a particular quarter. But since no activity will have occurred that should be reflected in the report provided (e.g., no change to the project’s completion status or to the amount of recovery funds expended or obligated to the award activities).
Is an administrative supplement received for a 2009 summer research experience eligble for a 12-month no-cost extension if the position was not able to be filled? (New: 08/10/2009)
Yes, a summer research experience administrative supplement received for 2009 may be extended for use in summer 2010. For a summer research experience supplement received for 2009 and 2010, a no-cost extension will allow it to be used for summers 2010 and 2011.

C. Competitive Revisions

How will the competitive revision applications be reviewed?
The locus of review (Center for Scientific Review or the ICs) will be the same as that of the parent grant to the extent possible. These applications will be reviewed in Special Emphasis panels.

How many pages are allowed for the Research Plan for competitive revisions?
The page limits for the Research Plan are the same as for the original (parent) grant. For R01s, that is 25 pages, for R21s, 15 pages, and for R03s, it is 10 pages. However, there is no need to use all the pages allowed, and it is expected that most competitive revision applications will use fewer than the maximum allotment. The page limit for the required introduction is one page for all applications.

Are R00 awards eligible for competitive revisions? (Updated: 04/07/2009)
R00 awardees are eligible as long as the supplement year(s) will not exceed the grantee’s three-year maximum for the R00 component. K99 awardees may receive 1 additional year of support through ARRA funds for a 6-year total K99/R00 award). Competitive revision applications to R00s must be submitted using a paper PHS398 application. No electronic submission capability currently exists for R00s.

If the parent grant is modular, but the budget for my competitive revision application exceeds $250K/year, do I still use the PHS 398 modular budget? (New: 04/07/2009)
No. If the competitive revision application requests more than $250K/year in any year, a detailed budget submitted on the SF424 Research & Related Budget form is required. Upon submission to Grants.Gov, a warning message will be generated, which can be ignored.
Where and in which format should competitive revision requests be submitted?
Competitive Revisions (formerly known as competitive supplements) should be submitted in the same format as is currently used for the parent grant. If the parent grant was submitted on paper but that activity has now transitioned to electronic submission, the competitive revision must be submitted in electronic format.

The application instructions administrative supplements are provided in the FOA, located at: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-09-058.html. The receipt date is April 21, 2009.

Is there a limit on the number of revisions that can be requested under a single award?
Only one competitive revision may be submitted for each parent grant. If the parent grant is a multi-component award (P01, P30, etc.), competitive revision applications for all components must be submitted as a single application with the PD/PI of the overall parent grant as the PD/PI.

An application that was initially submitted as a R01 was converted at the time of award to cooperative agreement (U01). How should a competitive revision application be submitted?
The award was issued as a cooperative agreement; therefore the revision application should be submitted as a U01 and in paper PHS398 format. However, you are encouraged to consult with your program officer to determine whether the specific IC is accepting competitive revision applications for cooperative agreements.
For applications which require the PHS398 (paper), is the April 21 due date a “receipt date” or a “send by” date? (New: 04/14/2009)
April 21 is a Special Receipt Date for the competitive revisions. Applications in response to announcements with special receipt dates must be received at NIH by the specified date.

IV. No-Cost Extensions

A. General

Can a terminated grant be retroactively extended so that it can be eligible for an ARRA administrative supplement or competitive revision?
No. NIH Institute/Centers will not accept requests for retroactive no-cost extensions for this purpose.

Can an administrative supplement or competitive revision be paid during the no-cost extension period of the parent?
Administrative supplements may be awarded to grants during a no-cost extension; however, the period of support cannot extend beyond the award period for the additional time that was granted. Note that while NIH recommends that a no-cost extension already be in place before an administrative supplement request is submitted, this is not a requirement for all administrative supplement requests.

To be eligible for a competitive revision, the parent grant must be active at the time revision application is submitted and the research proposed in the revision must be accomplished within the current competitive segment. That said, the period of support requested for the revision cannot exceed the current project period end date of the parent grant, including projects on a no-cost extension. Also, a no-cost extension must be in place before the revision application is submitted.
My grant is in its final year and will expire August 31, 2009. My institution plans to authorize a no-cost extension; however, the eRA Commons Project Extension feature doesn’t permit these notifications to be submitted until 90 days prior to the end date. Will the Commons feature be modified to accommodate earlier notifications for ARRA?
No. The possibility of an ARRA Administrative Supplement or Competitive Revision in itself is not adequate justification to authorize an early no-cost extension. Instead the decision to extend the final budget period should be made close to the actual expiration date once there is knowledge about the actual need for additional time to complete the approved and funded scope. Remember this is a no-cost extension; thus the rationale for executing this authority continues to be based on the understanding that: 1) no additional funds are required to be obligated by the NIH; 2) the project’s originally approved scope will not change; and 3) that either additional time is needed to ensure adequate completion of the original approved project, continuity is required while a renewal application is under review, or the extension is necessary for an orderly phase-out of the project that will not receive continued support. These core principles remain, even with ARRA.

B. No-Costs Extensions and Administrative Supplements

My grant only has 6 months left in the final year. Can I request a no-cost extension for 18 months so that I’m eligible for the 24-month administrative supplement?
No. Not all administrative supplements will be 24-month awards. While the availability of the ARRA funding is for 2 years, actual awards will be consistent with the time remaining in a particular project period; not to exceed 24 months. For grants already in their final year, grantees should be mindful of the available time remaining when preparing such requests.

The NIH Guide Notice on ARRA Administrative Supplements (NOT-OD-09-056) implies that a grantee doesn’t need to have the extension in place at the time the request is submitted. What should grantees do in the situation when the grant expires 8/31/2009, we know we will extend the grant, but can’t do so in the Commons until June 1, 2009 (after the submission date for Administrative Supplements)?
In this case, the grantee could include information about their plans to extend the grant as part of the ARRA Administrative Supplement application. The Administrative Supplement request can then cover the entire time, including the expected extension. However, the grantee will still need to use the eRA Commons feature to execute the no-cost extension when appropriate. The NIH IC will not process the request for the grantee.
For my grant, the no-cost extension possibility isn’t “imminent”; my final year was just awarded in February 2009 with a final budget period of 3/1/2009 – 2/28/2010). Can I still include plans to extend the grant next year in my ARRA Administrative Supplement Request?
Technically yes. However, caution should be exercised when planning a no-cost extension for a grant that won’t expire until next fiscal year. A lot can happen in that timeframe, including the successful competition of a renewal application. In this case, the more prudent approach might be to submit the Administrative Supplement request reflecting the known period remaining; without any expected extension. In cases where it is unknown how much additional time will be needed to complete the approved and funded scope, the grantee will still be responsible for executing the no-cost extension next fiscal year through the eRA Commons.

C. No-Cost Extensions and Competitive Revisions

The Competitive Revision Notice indicates that any no-cost extension must already be in place at the time of application. My grant is in its final year and will expire August 31, 2009. My institution plans to authorize a no-cost extension; however, the eRA Commons Project Extension feature doesn’t permit these notifications to be submitted until 90 days prior to the end date. Can I apply for a Competitive Revision that includes the expected no-cost extension?
No. Policy (enforced by electronic validations) requires that the competitive revision application be proposed to end on the same date as the currently funded project period. There is no flexibility available for competitive revisions; the scope of the proposed research must reflect the time remaining in the current project period. Remember that competitive revisions will be subject to peer review. If what is being proposed extends beyond the current end date of the project; perhaps a Competitive Revision is not the best solution. One should consider a traditional renewal application or using some of the unique ARRA opportunities that have been announced, like the Challenge Grant, if appropriate. Finally, depending on the nature of the proposed work, an ARRA Administrative Supplement request might be an appropriate option.

For my grant, the no-cost extension possibility isn’t “imminent”; my final year was just awarded in February 2009 with a final budget period of 3/1/2009 – 2/28/2010). Can I still include plans to extend the grant next year in my ARRA Competitive Revision application?
No. Policy (enforced by electronic validations) requires that the competitive revision application be proposed to end on the same date as the currently funded project period. There is no flexibility available for competitive revisions; the scope of the proposed research must reflect the time remaining in the current project period. Remember that competitive revisions will be subject to peer review. If what is being proposed extends beyond the current end date of the project; perhaps a Competitive Revision is not the best solution. One should consider a traditional renewal application or using some of the unique ARRA opportunities that have been announced, like the Challenge Grant, if appropriate. Finally, depending on the nature of the proposed work, an ARRA Administrative Supplement request might be an appropriate option.

V. Biomedical Research Core Centers (P30)

A. General

For a Biomedical Research Core Center (P30) or other application that will involve human subjects, but the nature of the research is human subjects research indefinite, how should the Human Subjects Research section (section E) be prepared? (New: 05/29/2009)
The PHS 398 application guide provides the following instructions for applications involving Human Subjects research:
In rare situations, applications are submitted with the knowledge that human subjects will be involved during the period of support, but plans are so indefinite that it is not possible to describe the involvement of human subjects in the application. The kinds of activities that lack definite plans are often institutional awards where the selection of specific projects is the institution's responsibility, research training grants, and projects in which the involvement of human subjects depends upon completion of instruments, animal studies, or purification of compounds.

If the involvement of human subjects is indefinite, create a heading entitled “Protection of Human Subjects” and provide a detailed explanation why it is not possible to develop definite plans at this time. The explanation should be specific and directly related to the Specific Aims in the application. If the involvement of human subjects depends upon information that is not presently available (e.g., completion of instruments, animal studies, purification of compounds), be explicit about the information and the factors affecting the availability of the information. Describe the information that will be necessary in order to develop definite plans for the involvement of human subjects, why that information is not currently available, and when the information is expected to become available during the course of the project.

Similar guidance is given for research involving Vertebrate Animals in the PHS398 application guide:
If the involvement of animals is indefinite, provide an explanation and indicate when it is anticipated that animals will be used.

VI. Recovery Act Section 1512 Recipient Reporting (New: 07/30/2009)

A. General

To whom do the reporting requirements apply?
All ARRA-funded, NIH extramural grant or cooperative agreement recipients must report information in accordance with Section 1512 of the Recovery Act on a quarterly basis using the www.FederalReporting.gov Web site. According to Section 1512 of the Recovery Act, prime recipients are responsible for fulfilling the reporting requirements for both prime and sub-recipients; however, prime recipients may delegate the reporting responsibilities to sub-recipients. In case of NIH-awarded grants or cooperative agreements, the prime recipient is the grantee institution. In cases where the prime recipient enters into a legal consortium or subcontract arrangement with another institution whereby the reporting terms would flow down to that other institution, that institution would be considered a sub-recipient. See the appendix of the OMB Guidance for definitions of recipients and sub-recipients.
What is the role of the PI in reporting?
This may vary depending on the procedures established by the grantee institution. The institution is considered the grantee and is responsible for determining processes within the institution for completing the reporting requirements. The PI may or may not be involved.
FederalReporting.gov is not currently operational. When will it be available?
Per OMB, the Web site is expected to be available on August 17, 2009 for registration and will be available for reporting on October 1, 2009.
How long does the recipient have to enter data?
The reporting window lasts from the 1st to the 10th of each reporting month. For the upcoming reporting period, this will be from October 1, 2009 to October 10, 2009. In addition, the 11th – 21st day of each reporting month is available for recipients to review the data submitted and make any necessary corrections. On day 22 of the reporting month, all data submitted will be “locked” and cannot be modified unless “unlocked” by the Federal awarding agency.
What can prime recipients do now to prepare for the October 1st to 10th reporting period?

• Institutions (not individuals) should register with the Central Contractor Registration (CCR) database if you have not done so previously.
• Register with www.FederalReporting.gov; registration is expected to open on August 17, 2009.
• Within your institution, determine what systems you will need to access to accommodate this reporting requirement. This could include purchasing systems, accounting systems, human resources/personnel systems, etc. Also, determine who within your institution will be responsible for the reporting requirement. Establish a consistent process and procedures to ensure that required reports are complete, consistently prepared, and accurate.
• When sub-recipients are involved, determine if you will be delegating the reporting requirement to the subs. If not, establish a procedure for collecting information from sub-recipients and vendors to fulfill the reporting requirements. Reporting spreadsheets are expected to be released very shortly and will be available on www.Recovery.gov.
• If you plan to delegate reporting responsibility to any of your sub-recipients, make certain any subcontract/consortium agreements are revised to document this responsibility. Also recommend that they prepare to register with FederalReporting.gov when registration is open.
What can sub-recipients do now to prepare for the October 1st to 10th reporting period?

• Obtain a DUNS number if you do not have one already
• Work with prime recipients to determine if you have been delegated reporting responsibility; this may vary depending on the prime recipient.
• Register with www.FederalReporting.gov; registration is expected to open on August 17, 2009.
• Within your institution, determine what systems you will need to access to accommodate this reporting requirement. This could include purchasing systems, accounting systems, human resources/personnel systems, etc. Also, determine who within your institution will be responsible for the reporting requirement. Establish a process to ensure compliance with these reporting requirements.
• Begin data collection to send to prime recipients or enter into FederalReporting.gov
What are the ramifications of non-compliance with the recipient reporting requirements?
Non-compliance of this reporting requirement will be treated as failure to comply with the terms and conditions of award and will be subject to the enforcement actions outlined in the Enforcement Actions section of the NIH Grants Policy Statement.
The OMB 6/22/2009 guidance document defines a recipient and sub-recipient as “non-Federal entities.” We have a consortium arrangement with a National Laboratory. Are they ineligible to receive ARRA funding?
In most cases the National Laboratory is a FFRDC (Federally-Funded Research Development Center) or GOCO (Government Owned/Contract Operated) facility. In these cases the prime recipient or sub-recipient is actually a contractor that is a non-profit University, industrial firm, or other non-profit organization. PIs and key personnel are employed by the contract organization, rather than the Federal agency. Since the grantee is actually the contractor (a non-Federal organization), OMB has indicated there is no concern with these organizations receiving ARRA funding as either a prime or sub-recipient.
Are there any pilots happening prior to the October 2009 report?
OMB is conducting a controlled, limited pilot to early test user experiences. This was scheduled to happen during July 2009. Institutions and agencies involved in this effort have already been identified.
It would appear that most of the data being requested is already being reported by Federal agencies under the requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Why do recipients have to provide data that is already available from Federal agencies?
Federal agencies are working with OMB to see where pre-population of data from agencies is possible. This will help ensure better data quality. However, it is unknown at this time how much pre-population will be available for the October 2009 quarterly report. In the interim, NIH and HHS are considering developing a tool that will provide as much of the data as possible from either the NIH eRA database or the HHS TAGGs database. More information about HHS TAGGS can be found at: http://taggs.hhs.gov.
How does a recipient access the FederalReporting.gov helpdesk?
The helpdesk contact information will be available on the www.FederalReporting.gov Web site at the start of registration and will provide help with user functions related to the registration and reporting processes. Questions regarding specific Recovery awards or programs should be referred to the Federal Awarding Agency.
If recipients have a question that cannot be answered by the FederalReporting.gov helpdesk whom should they contact at NIH?
The NIH Grants Information help desk will be handling calls and inquiries on ARRA recipient reporting. Grantees should not routinely contact their assigned grants management specialist or program official on issues concerning this quarterly reporting requirement.
Where can I find recordings of the OMB Webinars conducted July 20-July 23, 2009?
Recordings of the Webinars are available at: http://www.whitehouse.gov/Recovery/WebinarTrainingMaterials/.
How will the reports entered into FederalReporting.gov be made available to the public?
On the 30th day of each reporting month, all reports will be made available on www.Recovery.gov and on individual Federal agency recovery Web sites.
My institution received an ARRA award from NIH, but then the PI moved so the entire award was cancelled. Must we still comply with the Section 1512 report?
No. If the award was cancelled, there is no requirement to include the project in the quarterly report.
Will institutions receiving awards just before the reporting period need to include those in the quarterly report? For instance, for the first report due in October 2009, will institutions have to include those awards just issued in September 2009?
At this time, the answer is yes. All awards issued prior to the reporting due date will be required to be included in the quarterly report. Therefore, for the October 2009 report, all NIH awards issued on or before 9/30/2009 must be included. However, NIH anticipates that no activity would be reportable for such awards. Consequently, it would be acceptable to indicate “Not Started” for the Project Status and “0” for the Number of Jobs. NIH also plans to take into consideration this timing issue as part of our review of the data submitted.

B. Registration

My institution is already registered in CCR and Grants.gov. Do we need to separately register in FederalReporting.gov?
Yes, separate registration in FederalReporting.gov is required.
How do recipients register to use FederalReporting.gov?
Recipients should register with www.FederalReporting.gov well in advance of the October reporting window. It is expected that FederalReporting.gov will be open for registration beginning August 17, 2009. You only need to register once. To register, prime and sub-recipients must have a Dun & Bradstreet (DUNS) number, and prime recipients must be registered in the Central Contractor Registration (CCR) database. Recipients who do not already meet these requirements should take immediate steps to prepare for registration. Further detailed information on CCR and D&B is available at http://www.ccr.gov/FAQ.aspx and http://fedgov.dnb.com/webform.
Who should I contact with registration questions?
The registration and reporting processes will be supported by a new FederalReporting.gov helpdesk. Contact information for the new support team will be available at www.FederalReporting.gov once registration opens.

C. Data Entry

How does a recipient submit reports into www.FederalReporting.gov?
There are two methods available to submit reports into FederalReporting.gov for the October 2009 report. The reporting organization can choose the most convenient method for reporting among the following:

• Online data entry in a Web browser: The Web site provides a straightforward data entry form, available via the user’s Web browser, for report data entry.

• Excel spreadsheet: The Web site will make a Microsoft Excel spreadsheet available for report submission. The user can download this spreadsheet, open the spreadsheet in Microsoft’s Excel spreadsheet program and fill it in.

More information on each of these methods is available in Section 3.6 of the OMB guidance document. Note: the OMB guidance includes a third option for using XML; however, it does not appear this option will be available for the October 2009 report.
Will there be an option for FederalReporting.gov pre-population of the Microsoft Excel spreadsheet?
No. FederalReporting.gov will pre-populate some data elements as noted in the Data Model; however, this will only be available for those recipients using the online data entry option.
How long does the recipient have to enter data?
The reporting window lasts from the 1st to the 10th of each reporting month. For the upcoming reporting period, this will be from October 1, 2009 to October 10, 2009. In addition, the 11th – 21st day of each reporting month is available for recipients to review the data submitted and make any necessary corrections. On day 22 of the reporting month, all data submitted will be “locked” and cannot be modified unless “unlocked” by the Federal awarding agency.
In Section 2.3 of the OMB guidance (page 10) there is a sentence indicating “Administrative costs are excluded from the reporting requirements.” Does this mean the administrative portion of F&A/indirect costs should not be reported?
No. Grantees are required to report on the total costs awarded, which include both direct and F&A/indirect costs. OMB will issue a clarification on what is meant by “administrative costs” in this context. However, it does not mean the administrative portion of F&A.
How does a recipient make a report correction to a submission?
A recipient may decide, or may be asked by a subsequent reviewer, to make a correction to a submission. The entity submitting the report is the data owner of the submission and is therefore responsible for applying any corrections. If the data was submitted in an online form, the data fields can be modified and saved. If submitted via Excel spreadsheet file, a new file with corrections will need to be uploaded. Recipients will have until the 21st of each reporting month to make corrections. After that date, the data will be locked and cannot be modified by the recipient unless the Federal agency unlocks the data. In the event a correction is noted after the data becomes public on the 30th of the reporting month, recipients will use the next quarterly report to make the correction.
What is a TAS and where can a grantee find this for a particular award? (New: 08/13/2009)
TAS stands for Treasury Account Symbol; a unique number for each Institute/Center (IC). A TAS number look-up tool is provided on the Excel spreadsheet reporting template. Tip: All NIH IC TAS numbers begin with 75. The TAS should be entered as follows: 75-XXXX. For example, an award from the National Cancer Institute would be entered as 75-0850. Note: Not all the codes in the look-up tool that begin with 75 are for NIH awarding components. Recipients should only use the code associated with the IC assigned to a particular award.

We expect recipients directly entering data into FederalReporting.gov will have a similar tool or a drop-down list of values from which to choose the appropriate TAS number. A table of TAS numbers for each IC is also available at http://grants.nih.gov/recovery/recipient_reporting.html.
If a grant is for construction, should the recipient use TAS number 75-0589 Building and Facilities? (New: 08/13/2009)
No. For constructions grant awards, recipients should use 75-0847 for the National Center for Research Resources.

D. Job Creation Estimates

What is the difference between a job created and a job retained?
A job created is a new position created and filled or an existing unfilled position that is filled as a result of the Recovery Act; a job retained is an existing position that would not have been continued to be filled were it not for Recovery Act funding. A job cannot be counted as both created and retained.
Are “Jobs Created” and “Jobs Retained” reported separately?
No. These are combined as a single data element titled “NumberOfJobs” in the Data Model. Even if the prime delegates other reporting responsibilities to the sub-recipient, the NumberOfJobs data element is not separately reported by the sub-recipient.
Who reports the job figures for sub-recipients—prime recipient or sub-recipients?
This will be the responsibility of the prime recipient to report as a single, combined number.
How are full-time, part-time and temporary jobs reported?
The estimate of the number of jobs required by the Recovery Act should be expressed as “full-time equivalents” (FTE), which is calculated as total hours worked in jobs created or retained divided by the number of hours in a full-time schedule, as defined by the recipient (see pages 35-36 of the OMB guidance document for more information). The FTE estimates must be reported cumulatively each calendar quarter.
Can percentage effort be used to measure FTEs instead of hours?
Yes. An alternative calculation based on the allocable and allowable portion of activities expressed as a percentage of the total is acceptable for recipients of assistance agreements that must comply with OMB Cost Principles (such as Circular A-21, Cost Principles for Educational Institutions and circular A-122, Cost Principles for Non-profit Organizations). For example, a full-time faculty member charging 50% effort on an ARRA award will be counted as .5 FTE. Hourly and part-time employees shall be calculated based on actual hours worked on the sponsored agreement and the institution’s definition of a full workload for employment.
How are NRSA trainees/fellows counted?
Although NRSA trainees and fellows are not considered employees of the grantee institution, for the purposes of the Section 1512 reporting these positions should be reported as Jobs Created/Jobs Retained. One full-time appointment for 12 months would equal 1.0 FTE for the number of jobs; a full-time appointment for only 6 months would equal 0.5 FTE.
Is the job figure a cumulative figure? Would you expect it to grow each quarter?
The job figure is a cumulative figure; however, the number of FTEs does not necessarily have to grow each quarter. For an example refer to page 35 of the OMB guidance document.

E. Data Review

What is the timing of the review period?
From the 11th to the 21st of the reporting month, reports are reviewed by the prime recipients. This review is particularly critical when a prime has delegated reporting requirements to sub-recipients. If a prime recipient notes a mistake in a sub-recipient’s report, they must contact the sub-recipient and have the sub-recipient make the correction. Only the party who initially submitted the report is able to make changes. NIH can see the data at this time and due to the limited time available for agency review may actually begin a preliminary review prior to the 21st. Beginning on day 22 of the reporting month, the reports are locked from further changes, and NIH has 7 days to conduct their review. If a change is needed during this period, a notification will be sent to the recipient describing the discrepancy. Note: even if the prime recipient has delegated this reporting requirement to sub-recipients, NIH’s communication will be with only the prime recipient. This notification also serves to unlock the report so it can be changed by the recipient. Any changes must be transmitted by the 29th of the month. On day 30 of the reporting month, regardless of the review status, the reports are published on Recovery.gov.
What will NIH look for during their review of recipient reports?
NIH will initially be reviewing for material omissions and significant errors as defined in the OMB guidance document. However, we expect this to be an evolving process and will adapt our level of review as time and experience suggests.
What is the definition of a material omission?
Material omissions are defined as those instances where required data is not reported or reported information is not otherwise responsive to the data request and such reporting gaps result in significant risk that the public will be misled or confused by the recipient report in question. For example, a recipient required to report a description of a purchase made from a vendor may not provide sufficient detail in the description for the reader to derive the nature of the purchase.
What is the definition of a significant reporting error?
Significant reporting errors are defined as those instances where required data is not reported accurately and such erroneous reporting results in significant risk that the public will be misled or confused by the recipient report in question. An example of this would be a recipient, or sub-recipient, who reports expenditures in excess of the amount awarded by the Federal funding agency, excluding funding resulting from match requirements.
The “FedExpenditure” data element will not reconcile with the number that will be reported for the quarterly PMS272 cash transaction report. Is that a problem?
Due to the timing of the required reports, it is recognized that the FedExpenditure figure reported for the Section 1512 quarterly report may differ from that submitted on the quarterly PMS272. Grantees should report figures to the best of their knowledge and ability at the time each report is due.
Who is responsible for the quality of data submitted under Section 1512 of the Recovery Act?
Prime recipients, as owners of the data submitted, have the principal responsibility for the quality of the information submitted. Sub-recipients delegated to report on behalf of prime recipients share in this responsibility. Agencies funding Recovery Act projects and activities provide a layer of oversight that augments recipient data quality. Oversight authorities including the OMB, the Recovery Board, and Federal agency Inspectors General also have roles to play in data quality. The general public and non-governmental entities interested in “good government” can help with data quality, as well, by highlighting problems for correction.
Is NIH required to certify or approve data for publication on Recovery.gov or agency Web sites?
No. NIH is required to run a data quality review process consistent with Sections 3 and 4 of the OMB guidance document. These actions are expected to occur prior to the 30th day of the reporting month. Reports will be posted on the 30th day after the end of the quarter regardless of the outcome of NIH data quality review efforts.
How will issues identified under the data quality reviews be communicated to the public?
Federal agencies will be required to classify submitted data using the following three categories:

• Not Reviewed by agency;
• Reviewed by agency, no material omissions or significant reporting errors identified; and
• Reviewed by agency, material omissions or significant reporting errors identified.

Within the third category, to the extent the agency identifies any data that it has reason to believe is false or misleading that has not been corrected by the recipient or sub-recipient, the Federal agency must provide such findings to recoveryupdates@gsa.gov so that the Recovery Board can make such instances public on the Web site www.Recovery.gov.

The system will automatically default to the first category of “Not reviewed by agency” if an agency has not chosen one of the above three categories before the 29th day of the process.

F. Questions Specific to NIH Administrative Supplement Programs

An administrative supplement for the summer research experience covers the summers of 2009 and 2010. Does the grantee need to report on the quarters in between the two summers when no activity will be ongoing?
Yes. However, it would be appropriate to show no change in activity for elements such as progress, amount expended, and number of jobs during the months between the two summers.

Also see: NIH Staff ARRA FAQs (NIH Staff Only)

Return to Recovery Act Funding Opportunities Page

This page was last reviewed on April 6, 2009

National Institutes of Health (NIH)
9000 Rockville Pike
Bethesda, Maryland 20892

Department of Health
and Human Services