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Updates from MUSC's Offices of Research Administration


NIH Notice NOT-OD-17-037

NIH Implementation

Effective February 9, 2017, if the recipient organization has submitted a renewal application on or before the date by which a Final Research Performance Progress Report (Final-RPPR) would be required for the current competitive segment, then submission of an "Interim-RPPR" via eRA Commons is now required.   Based on this requirement, the NIH will discontinue the policy for renewal applications whereby, “whether funded or not,” the progress report contained in the renewal application may serve in lieu of a separate final progress report. 

An Interim-RPPR link for the grant will appear in the Status tab in eRA Commons after the period of performance end date has passed. In the event that the renewal application is funded, NIH will treat the Interim-RPPR as the annual performance report for the final year of the previous competitive segment. If the renewal application is not funded, the Interim-RPPR will be treated by NIH staff as the institution's Final-RPPR. 

As stated in NOT-OD-17-022, the Interim-RPPR must be submitted via the eRA Commons no later than 120 calendar days from the period of performance end date. If a recipient fails to comply with this reporting requirement, NIH may take one or more enforcement actions, such as a decision to withhold a non-competing continuation award, consistent with NIHGPS Chapter 8.5.2. NIH will maintain the business rule in the RPPR module enabling institutional signing officials (SOs), at their discretion, to delegate submission of the Final RPPR or Interim-RPPR to the Program Director/Principal Investigator (PD/PI).

Further guidance is provided through the scenarios below outlining the process of when to submit a Final or Interim-RPPR.

Scenario

Status of Competing Renewal Application

Workflow Process

1

Competing Renewal not submitted

Submit a Final-RPPR no later than 120 calendar days from the period of performance end date.

2

Competing Renewal submitted

Submit an Interim-RPPR no later than 120 calendar days from the period of performance end date. If the competing renewal is funded, NIH will treat the Interim-RPPR as the annual performance report for the final year of the previous competitive segment.

3

Competing Renewal submitted but not funded

Submit an Interim-RPPR no later than 120 calendar days from the period of performance end date. If the competing renewal is not funded, NIH will treat the Interim-RPPR as the institution's Final-RPPR. To reduce burden NIH will not require recipients to submit an additional Final-RPPR if the renewal application is not funded.

 

Reminder: Effective January 2017, NIH requires recipients to report on Project Outcomes in Section I of the Interim and Final-RPPR. Therefore, in each scenario listed above, Project Outcomes must be provided by the recipient in order for the recipient to submit their final report in eRA Commons. Otherwise, eRA Commons will not allow recipients to submit the required report and recipients will be considered non-compliant.

NOTE: Implementation of the Final RPPR for Small Business Innovation and Research (SBIR) and Small Business Technology Transfer (STTR) grants will occur approximately 2 months after implementation for all other NIH grants due to unique final reporting requirements under the Small Business Administration's SBIR/STTR Policy Directive.