For subawards scheduled to receive continuation funding in FY2016 and set-up in task logic, confirm whether and how the subaward will be impacted by the transition BEFORE incurring any expenses after the end date of the FY2015 budget period. Recommend reviewing subaward, and confirming with PTE, if necessary, 60-90 days in advance of the FY2015 budget period end date. If the PTE will need us to request approval for carry-over as a result of the transition, a new subactivity for the transitioned award will be required.
Submit a request for pre-award authorization for the new P-Subaccount Fund if necessary to cover project costs incurred prior to the start date of the transition budget period. After the pre-award authorization is complete, you can process journal adjustments.
Subaccount transitional FFR is due within 90 days of the end of the FY15 budget period.
For awards that allow automatic carry-over, carry-over will need to be processed once the FFR has been submitted. OSP and SPA will work together to ensure that automatic carryforwards are processed timely after the FFR submission. There is no change in process for carryforward requiring prior approval.
Once the carry-over for the award has been processed, we will need to process the carry-over for any subawards.
Need a final invoice to close out the previous administrative segment within 60 days of the end of the FY15 budget period so that the Subaccount Transitional FFR can be prepared.
Once the new Fund has been established for the continuation funding, issue the subrecipient their continuation funding via an amendment, utilizing language and process for awards where carry-over is restricted (even if the transitioned award does not restrict carry-over).
If the prime award allows automatic carry-over, once...
Notify subrecipients under affected awards that the Federal award is being transitioned and appropriately modify the terms of the subaward for the transition year.
A. SPA to include the following text in the email transmitting the amendment for the FY2015 funding to the subrecipient:
“*SPECIAL NOTICE: As you may be aware, NIH is in the process of transitioning from a pooled draw system to use of Payment Management System (PMS) subaccounts (see NIH Guide Notice NOT-OD-14-103 available at http://...
Rather than issuing the transitioned award as a Type 5 as we would normally expect for a noncompeting award, NIH will issue the transitioned awards as a Type 4 (funded extension).
In the Notice, in the Fiscal Information section under Section 1 – Award Data, you will see that the award has received a new Document Number and the PMS Account Type will now be listed as P (Subaccount). For example:
As a general rule, awards for which the current competing segment was awarded prior to October 1, 2013 and that will be receiving continuation funding in FY16 (after 10/1/2015) will be affected by the transition. This means that primarily awards receiving the 4th or 5th year of funding in a competing segment will be impacted. You can also tell by looking at the most recent NoA. If the award still indicates that the award is under the G (Pooled) account type (see 3.b below), the award will need to be transitioned in FY16.