Frequently Asked Questions (FAQs)

Which assurances and public policy requirements are applicable to foreign institutions?

Section II.B.16 of the NIH Grants Policy Statement provides detailed information about assurances and Public Policy Requirements and Objectives as they relate to foreign organizations.

Also, Section II.A.4 of the NIH Grants Policy Statement provides a complete list of Public Policy Requirements, Objectives, and Other Appropriation Mandates as they relate to all institutions (foreign and domestic).

Examples include but are not limited to:

• Research Misconduct
• Animal Welfare
• Human Subjects
• Financial Conflict of Interest
• Inclusiveness in Research Design
• Lobbying
• Debt
• Debarment and Suspension

May foreign institutions submit modular budgets?

No. The detailed budget format is required for foreign institutions to allow NIH staff to assist with applicable regulatory and policy requirements for grant funding expenditures; therefore, modular budgets are not allowed from foreign institutions. However, domestic institutions with a foreign subcontract may use the modular budget format.

Are Federal Financial Reports (FFRs) required annually for SNAP awards to foreign institutions?

No. In accordance with "Notice of Changes to Policies and Procedures for FY2013 NIH Awards to Foreign Institutions" (NOT-OD-12-139), Federal Financial Reports (FFRs), formally called Financial Status Reports (FSRs), are no longer required annually for SNAP awards issued after October 1, 2012 to foreign institutions. A final FFR is required only at the end of a competitive segment.

What information do I need to include in the progress report for my Fogarty grant?

Fogarty provides detailed supplemental guidance for completing progress reports specific to Fogarty grantees. Refer to the guidance for your award type (Standard, Education or Career) based on the grant award activity code (e.g., D43, K01, R01).

Is the Responsible Conduct Research (RCR) policy applicable to foreign institutions?

Yes. The Responsible Conduct Research (RCR) policy is applicable to all projects that require instruction in responsible conduct of research as noted in the Funding Opportunity Announcement, whether domestic or foreign. For more information refer to "Update on the Requirement for Instruction in the Responsible Conduct of Research" (NOT-OD-10-019).

Who needs an eRA Commons account?

Individuals needing scientific roles (Program Directors, Principal Investigators, Scientist, Post-Doc, Graduate Students, Undergraduate Students, Project Personnel) should only have one eRA Commons role for the life of their research career.

When do grantees need to submit an Interim-RPPR (I-RPPR) or Final RPPR?

Grantees should submit an Interim RPPR when submitting a renewal (Type 2) Competing Continuation application. If the Type 2 is not funded, the Interim RPPR will serve as the Final RPPR for the last competitive segment.

If the Type 2 is funded, the Interim RPPR will serve as the annual RPPR for the final year of the previous competitive segment. The data elements collected on the Interim RPPR are the same as for the Final RPPR, including project outcomes.

Can domestic institutions that don’t have a negotiated indirect cost rate use the de minimis indirect costs (F&A) rate and not negotiate a rate? (Foreign grants, Career Awards, and D71, U2R and D43 training grants can’t use this rate.)

Consistent with 45 CFR 75.414(f), any institution of higher education (IHE), nonprofit organization, or state or local government that has never received a negotiated indirect cost rate, except for those non-federal entities described in 45 CFR 75, Appendix VII, Section (D)(1)(b), may elect to charge a de minimis rate of 10% of modified total direct costs (MTDC) which may be used indefinitely. As described in 45 CFR 75.403, costs must be consistently charged as either indirect or direct costs but may not be double charged or inconsistently charged as both. If chosen, this methodology once elected must be used consistently for all Federal awards until such time as a non-Federal entity chooses to negotiate for a rate, which the non-Federal entity may apply to do at any time.

How do foreign institutions receive grant funds?

Awards to foreign institutions and international organizations issued after October 1, 2012 are paid through the Payment Management System (PMS), according to the "Notice of Changes to Policies and Procedures for FY2013 NIH Awards to Foreign Institutions" (NOT-OD-12-139). The contact person at PMS responsible for these payments is Ms. Raynette Robinson, who may be reached at raynette.robinson@psc.hhs.gov or 301-492-4938.

How should domestic grantees pay foreign consortium or subcontract costs?

Many foreign institutions have unique fiscal needs and/or may not have the infrastructure to pay award costs prior to receiving grant funds. Therefore, it may be reasonable for U.S. grantee institutions with a foreign consortium to provide the foreign institution quarterly advances of funds or arrange a reasonable payment schedule to accomplish the goals of the NIH grant. Ultimately, payment arrangements are subject to the grantee's institutional policies and should be clearly defined in the Consortium Agreement.

May funding requests be made in foreign currency and then be converted to U.S. dollars?

No. All requests for Funding and Payment, including the budget contained in the application, must be stated in U.S. dollars. Once an award is made, the NIH Institute or Center (IC) staff will consider requests to compensate foreign grantees for currency exchange fluctuations only when the change results in the need of additional federal funding; or when the increased costs result in the need to significantly reduce the scope of the project. These requests will only be considered if the NIH IC has funds available.

Do foreign institutions have to negotiate a Facilities and Administrative (F&A) cost rate agreement with NIH to receive F&A costs of up to eight percent of the total direct costs (less equipment)?

No. Foreign institutions do not need to negotiate an F&A rate. NIH continues to fund F&A costs under grants to foreign and international organizations at a rate of 8 percent of modified total direct costs, exclusive of tuition and related fees, direct expenditures for equipment, and subawards in excess of $25,000. These funds are paid to support the costs of compliance with federal requirements. Some examples of NIH compliance requirements are the protection of human subjects (including the required education in the protection of human research participants), animal welfare, invention reporting, other post-award reporting requirements, financial conflict of interest and research misconduct. Note, these are just a few representative examples of compliance requirement; this list is not all inclusive. Awards to domestic organizations with a foreign or international consortium participant may include 8 percent of modified total direct costs, exclusive of tuition and related fees, direct expenditures for equipment, and subawards in excess of $25,000. These funds are paid to support the costs of compliance with federal requirements. NIH will not support the acquisition of or provide for depreciation on any capital expenses (facilities) or the normal general operations of foreign and international organizations. Therefore, these expenses may not be requested as a direct cost; however, equipment is an allowable direct cost. Other items normally treated as F&A costs (e.g., rent) may be requested as direct costs and will be evaluated by NIH for allowability.

What do grantees do with interest earned on grant funds?

All grantees are required to maintain advances of grant funds in an interest bearing account.

The Funding and Payment policy as it applies to foreign institutions is that interest earned in excess of US$500 per year in the aggregate on advances of Federal funds must be returned by reimbursement check to the NIH Office of Financial Management (OFM), and reflected on the annual Federal Financial Report (FFR).

Refer to the NIH Grants Policy Statement for the general policy on Interest Earned on Advances of Grants Funds, regardless of foreign or domestic status.

What is program income?

Program income is gross income earned by a grantee, a consortium participant, or a contractor under a grant that was directly generated by the grant-supported activity or earned as a result of the award. Refer to the NIH Grants Policy Statement for more details about Program Income.

Are visa costs allowed on grants?

Visa costs may be allowable when identified in specific FOAs, or when within the scope of an approved research project. Generally allowable direct cost as part of recruiting costs on an NIH grant, as long as the institution has an employee/employer relationship with the individual.

Do I need NIH prior approval for all budget or project changes no matter how minor?

No. Only certain changes in project and budget require NIH prior approval. Other changes should be handled internally according to the grantee institution's policies and procedures.

Foreign institutions are subject to the same administrative requirements regarding changes in project and budget as domestic grantees.

What is the NIH policy concerning the transfer of a grant to or between foreign institutions?

All requests for changes of grantee organizations require NIH prior approval regardless of whether the institutions involved are foreign or domestic.

A change of grantee organization that involves the transfer of a grant to or between foreign institutions or international organizations requires approval by the appropriate NIH Institute or Center's Grants Management Officer and approval of the Institute or Center's Advisory Council/Board.

A change of grantee organization that involves the transfer of a grant from a foreign organization to a domestic organization requires only the approval of the Grants Management Officer.

Is NIH prior approval required for adding a new foreign consortium or subcontract to a project?

Yes. Adding a new foreign consortium or subcontract always requires prior approval. Refer to the NIH Grants Policy Statement for more details about the transfer of the "Performance of Substantive Programmatic Work" to a third party by means of a consortium agreement.

May a grant with multiple Principal Investigators (PIs) be changed to a single PI?

Yes. In rare cases and with appropriate justification, a request to change from multiple PIs to a single PI (or vice versa) may be approved. The NIH Grants Policy Statement offers more information about Multiple Program Direct/Principle Investigator Applications and Awards.

The NIH Office of Extramural Research (OER) offers more information on the Multiple Principal Investigators policy page.

What is a change in scope and do I need to ask permission from the staff at the awarding NIH IC?

Please review information from Fogarty on changes in scope on NIH grants and cooperative agreements.

Do I have to use certain airlines when staff travel on a NIH grant?

Yes. Please see information from Fogarty on the NIH policy for foreign travel on NIH grants.