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NIH’s Incorporation of Uniform Guidance

On March 31, 2015 NIH released the revised NIH Grants Policy Statement incorporating the new Uniform Guidance. All NIH grants, cooperative agreements, and supplements with a budget period beginning on or after December 26, 2014 now have this version of the Grants Policy Statement as a term and condition of your award.

As you may know, on December 19, 2014, the Department of Health and Human Services (HHS) released its implementation of the Office of Management and Budget’s new Uniform Guidance (UG). HHS-specific amendments to the UG are codified in 45 CFR part 75.

This HHS Interim Final Regulation went into effect on December 26, 2014; however, it allowed for a 60 day public comment period. Given the comment period, on February 5th, 2015, the National Institutes of Health (NIH) released its Interim Grant General Conditions summarizing changes to previous NIH grant policies as a result of 45 CFR part 75. Now that the comment period has ended, NIH released a revised Grants Policy Statement incorporating HHS’ implementation of the Uniform Guidance which supersedes the NIH Interim Grant General Conditions.

However, please note that the October 2013 Policy continues to be the standard term and condition for all NIH grants and cooperative agreements with budget periods that began between October 1, 2013 and December 25, 2014.

Please note (unless specified otherwise in the Notice of Award):

  • All NIH awards providing new or supplemental funding on or after December 26, 2014 fall under the new NIH Grants Policy Statement implementing the UG per 45 CFR part 75.
  • The new guidance will apply to carryover of NIH funds originally awarded prior to December 26, 2014 if a new Notice of Award is received citing the new guidance (45 CFR part 75).
  • The new NIH Grants Policy Statement contains important changes including:
    • New recipient authorities (e.g., conditions for allowability of costs for computing devices, administrative clerical staff);
    • New prior approval requirements (e.g., rebudgeting of cost share); and
    • Stricter protocol for sub-awarding funds to grantees.

The implementation of the Uniform Guidance is taking shape for both HHS and NIH, but perhaps most crucial is to note the effective date of the UG was more than three months ago, and UT has federal awards in-hand falling under the new rules.

For further details, please see the full text of the revised NIH Grants Policy Statement:
http://grants.nih.gov/grants/policy/nihgps/index.htm

A document summarizing the significant changes implemented with the 2015 Policy is available at:
http://grants.nih.gov/grants/policy/nihgps/Significant_Changes_NIHGPS.pdf.

Visit NIH’s Frequently Asked Questions (FAQs): http://grants.nih.gov/grants/policy/faq_grants_uniformguidance.htm#

Also, please see Notice # NOT-OD-15-087 for NIH’s general announcement and links to related notices:
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-15-087.html

If you have questions or comments, please contact Betsy Saylor at 865 974-3863.