So What’s So Special About June 1?

May 15, 2012 | By Jerry Ashworth | Post a Comment

If you are a recipient of American Recovery and Reinvestment Act award funding from the National Institute of Health and you expect to continue spending funds past September 2013, your deadline for submitting a waiver to do so is fast approaching.

The Obama administration issued a memorandum last fall requiring federal agencies to accelerate spending of all Recovery Act funding by Sept. 30, 2013, although grantees may submit a request for a waiver to extend their award past that date. Michelle Bulls, deputy director of the NIH Office of Policy for Extramural Research Administration, told attendees at Monday’s Federal Demonstration Partnership meeting that all requests from NIH grantees seeking a waiver must be submitted to the agency on or before June 1 (Hey, consider yourselves lucky — National Science Foundation grantees were required to submit their waiver requests in March). The NIH will then submit the requests to the Office of Management and Budget for approval. Bulls warned that a request for a waiver request does not guarantee that the waiver will be granted.

Specifically, NIH recipients must notify the grants management officer listed on the notice of award in writing that an extension of the final budget period of the project is vital for the completion on the project. The NIH and OMB have stated that waivers may be provided in light of the following circumstances:

  • the project is long-term by design and acceleration would compromise core programmatic goals;
  • the project must undergo complex environmental review that cannot be completed within this timeframe;
  • contractual commitments between the awardee and vendors/subrecipients legally prevent adjusting the timeline for spending; and
  • special circumstances exist where acceleration may cause unnecessary harm or unreasonable risk to vertebrate animals or human subjects involved in the research (such as in ongoing clinical trials).

So if you’re a researcher with NIH Recovery Act funding, plan now to submit a waiver if you think your project meets these criteria. But hurry, you don’t have much time.

Also, as an update from a blog post last week, we found out that the 2012 OMB Circular A-133 Compliance Supplement may be coming out soon. OMB officials have said they expect to release the Compliance Supplement by May 31. The OMB issued it on June 1 last year so this would be consistent (if it’s actually released on that date), yet stakeholders are clamoring for the supplement to come out earlier. With the potential for grant management and single audit reform on the distant horizon, I don’t expect the Compliance Supplement to come out any earlier next year or in future years. Will we ever see the day when OMB issues the Compliance Supplement in March? I’m not holding my breath for it.

Do you expect there will be a great need for Recovery Act waivers or can the funds be spent on time? Also, any reaction to the Compliance Supplement’s expected delivery date? Let us know.  



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