The Fallout from October Has Just Begun: Here’s What You Need to Know

United States Capitol BuildingSHUTDOWN FALLOUT

Congress has opened its doors for business again after a two-week political roller coaster ride. The impact of this legislative hissy fit, however is still being assessed. While the media has focused on the patients in Washington DC that weren’t registered for trials at the NIH (truly a heartache) and the researchers in Antarctica and other extreme climes, research administrators have feverishly worked to meet a crushing load of November application deadlines.

In addition, research administrators and faculty have worked to assess the impact of missed application reviews on previous submissions from the last cycle, and how this will impact the upcoming review schedules. Meetings for 200 review committees scheduled for October at the NIH were canceled during the shutdown, and the impact of rescheduling these meetings (and therefore bumping the schedule of awarding these grants and holding future reviews for the upcoming cycle) is breathtakingly frightening for academic institutions across the country. Fortunately reviewers stepped forward and have volunteered to make time to participate (as institutions like the NIH originally announced revised schedules several months out, causing widespread alarm). NIH reviews are resuming in January instead of May.

NEW PAYMENT MANAGEMENT SYSTEM AT NIH

As if the shutdown didn’t give us enough excitement to manage, we are looking to the new NIH payment images (1)management system which is going into effect as we speak. The new payment management system is a process that accomplishes 2 things. First, it allows the NIH to transition current domestic awards from PMS pooled accounts (type G) to a new type of account called a PMS type G subaccount. Second, it will allow the NIH to award all new grants and contracts as the PMS type G subaccount and allow the agency to administer all awards with new payment management rules.

Starting in November, notices of award will list the type of award (type P or G). To facilitate the transfer process, the NIH will transfer new awards into the new PMS system in FY14 (which has already started. In FY15, the NIH will transfer continuing awards.

hound dogSome changes to the management of awards and closeouts have already taken place, and if you don’t know about them, you should:

1. Depending on your institution’s standard operating procedures, the NIH policy previously afforded additional time for reconciling and closing out the award before completing the annual or final financial report. The new policy requires that awards be ready for closeout at the end of the award period for a prompt production of the annual or final financial report. If your expenses have not hit the proper account when they were supposed to, you will not have enough time to fix it at the end of the budget period or award period.

2. As awards shift from the old to the new payment system, competitive segments will be shortened for one year and new awards will be given new identifiers on the NOA. Get ready for some fancy footwork – tracking and reporting on these awards will be F-U-N.

3. Prepare to bid goodbye to unliquidated obligations from previous award segments/periods. Either encumber funds, and use them, or plan to lose them at the end of the budget period. PERIOD. The new FFR format calls out the unexpended balance from prior project period right up front. (They might as well call it “funds to cut from this project budget”).

4. Automatic carry forward can be requested – but funds are not permitted to be drawn down until they are formally approved and appear on the new NOA. (Read between the lines: carry forward isn’t so automatic anymore.)

These new requirements require a laser focus on direct charging salary to sponsored projects, and encumbering salary and project expenses appropriately to awards. Research administrators need to reconcile projects on a monthly basis to ensure that charges are hitting correctly to have the grants and contracts awarded to their investigators managed to a successful close.

AN END TO SEQUESTRATION?

Congress is talking now about how they will come together in January to pass a budget – and believe it or not, they are talking about adjusting the terms of the sequester. It’s hard to believe that sequestration is back on the table (for more information about sequestration, check out my previous post). Everyone seems to agree that the across-the-board cuts have been a disaster, but, as you can guess, nobody in Congress agrees on a way to restore cuts in a fashion that can be voted on to pass in both the House and the Senate. (Does this sound familiar?) While it would be fantastic to have improvements in sequestration funding, and there appears to be bi-partisan support for doing so, this seems to be linked to passing a budget in January, and if that is the case, I’d put money on the likelihood of another government shutdown.

The DOD would be a likely target for increased funding (relief of sequestration) but its hard to tell how the NSF, NIH, FDA or other agencies would fare given the history of divisiveness that exists.

WHAT YOU CAN DO

  1. Assess your investigators’ research portfolios now; analyze your investigators’ salary and effort plans using the proposed data and effort certified to project out their current commitments if you haven’t already done this.
  2. Analyze the salary and effort of staff in the laboratories or on the projects that your investigators support.
  3. Assess the status of your investigators’ applications, if possible, to know where they are in the pipeline. Create a projection based on likelihood of funding, planned applications and current funding.
  4. Work with faculty and staff to assess potential gaps in funding for your faculty and staff. Begin to plan and request appropriate resources to cover faculty and staff salary and research during any time when the faculty member is not covered by sponsored funding.
  5. Create a budget and plan to support the request, and work with the faculty member and his/her department to request support.
  6. Assess institutional resources available to submit new applications early – should it be that we face additional gridlock in DC. Plan with your investigators to do this, if possible. (Adios, December!)
  7. Keep an eye on DC politics – and hope that this time around it’s not as bad. (Check out these resources from my previous post.)

By using our unique resources and perspective, we can help our institutions support the faculty and staff that are performing research in a wide variety of fields that make our world a better place to live. This is a really tough time, and we need to step up and make it possible for the research community to concentrate on their work – and not on the political struggles in Washington.

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