I’m having this interesting conversation with an NIH grants specialist. The issue is how they determine when a key personnel has decreased their effort by the 25%.
In this case, NIH is comparing my PI’s effort from his current grant year (via the progress report) to that reported last year. According to the grants policy manual, the determination of a significant decrease in effort should be compared to the original budget at the time of award.
For example, we’re in the PI’s third renewal period which began 3 years ago. The original renewal application proposed 100% effort of the PI. At the time of award the cut was so severe that the PI revised his scope of work as well as his budget to accommodate the cut. The budget was revised to bring his effort to about 60% for the life the renewal. Through careful planning, the PI managed to pull 100% effort/salary (it’s his only project) and we reported it in previous progress reports at 100%. This current grant year is different. In October he had to decrease is FTE to 50% because the grant could no longer support him at 100% and reported him in the progress report at a 67% (8 mths). NIH is asking for a justification as to why his effort was reduced by such a significant amount.
I’m saying that according to the grants policy manual, NIH should be looking to the revised budget submitted and approved at the beginning of the renewal period, which, actually, proposed a lower effort level than the 67%. The NIH specialist sent me verbiage from what appears to be the internal manual they use.
Before I reply back to NIH I’m wondering if anyone has had this issue? FYI, I did supply the justification for the reduced effort just so we can move forward in getting next year’s funding in, but that doesn’t mean this isn’t bugging me.
From the grants policy manual:
The grantee is required to submit a prior approval request to the GMO if the PD/PI or other senior/key personnel specifically named in the NoA will withdraw from the project entirely, be absent from the project during any continuous period of 3 months or more, or reduce time devoted to the project by 25 percent or more from the level that was approved at the time of initial competing year award (for example, a proposed change from 40 percent effort to 30 percent or less effort or in calendar months a change from 4.8 to 3.6 calendar months). Once approval has been given for a significant change in the level of effort, then all subsequent reductions are measured against the approved, adjusted level. NIH must approve any alternate arrangement proposed by the grantee, including any replacement of the PD/PI or senior/key personnel named in the NoA.
What the NIH grant specialist sent to me:
The GMS must track effort of the PD/PI and other Senior/Key Personnel who are listed on the NoA. The source of this requirement is the NIH Grants Policy Statement which requires prior approval of changes in status of senior/key personnel who are specifically designated in the NoA.
For awards eligible for eSNAP, the GMS should rely on the answer to Snap question #2, which is "Will there be, in the next budget period, a significant change in the level of effort for the PD/PI(s) or other Senior/Key Personnel designated on the Notice of Award from what was approved for this project?"
What should the GMS do if the All Personnel Report indicates a reduction of effort of 25% or greater for personnel named in the NoA, and for which the grantee did not request prior approval?
The All Personnel Report is retrospective and the grantee should have requested prior approval. The GMS should discuss this with the grantee, and obtain clarification of the reduction in effort and the date it was implemented. It is also suggested that you obtain the opinion of the Program Official, and that you document all discussions. This should be done prior to issuing the Type 5 award.
Kris
Kristina Duryea, MA, GCRA
Departmental Grants Administrator
Brookhaven National Laboratory
Medical Department, Bldg. 490
Upton, NY 11973-5000
631-344-7850 voice
631-344-2358 fax
xxxxxx@BNL.gov