Important Information Regarding ARRA Awards

On September 15, 2011, the Office of Management and Budget
http://osp.mit.edu/glossary/term/45 (OMB) issued Memorandum M-11-34,
“Accelerating Spending of Remaining Funds from the American Recovery and
Reinvestment Act.” The memo directed Federal agencies to accelerate the
spending of ARRA funds as a way to support the President’s ongoing
efforts to “drive the economy forward and create jobs” and to take steps
to complete Recovery Act projects by September 30, 2013.

Agency-specific guidance

The National Institutes for Health (NIH
http://osp.mit.edu/glossary/term/149 ) and the National Science
Foundation (NSF) have provided guidance on meeting the accelerated
spending goal. The key elements of that guidance follow. The NIH
guidance can be found at:
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-12-014.html
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-12-014.html .
The NSF guidance can be at: http://www.nsf.gov/recovery/acceleration.pdf
http://www.nsf.gov/recovery/acceleration.pdf .

NIH Guidance:

For awards scheduled to end on or BEFORE September 30, 2013

If a no-cost extension http://osp.mit.edu/glossary/term/150 is
necessary, it must be requested by JUNE 1, 2012, regardless of the end
date of the award. Grantees may still exercise their one-time,
grantee-approved no-cost extension as long as the period of performance
http://osp.mit.edu/glossary/term/160 with the extension does not
extend beyond September 30, 2013. However, if a Principal Investigator
requires an extension beyond September 30, 2013, he/she must follow the
guidance below for “awards that are scheduled to end after September 30,
2013.”

For awards that are scheduled to end AFTER September 30, 2013

If a no-cost extension is necessary, it must be requested by June 2,
2012. The NIH Grants Management Officer for the award must be notified
in writing via the appropriate Contract and Grant Officer in Sponsored
Projects of the request for an extension. The request for extension must
explain why an extension of the project is vital for its completion. NIH
must seek a waiver from OMB in order to approve the extension. The
criterion for a waiver is as follows:

* 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;

* 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).

The Standard Terms and Conditions for the award will be revised to
require sponsor approval to extend the award.

NIH strongly encourages grantees to responsibly accelerate spending.

NSF Guidance:

For awards scheduled to end on or BEFORE September 30, 2013

If a no-cost extension http://osp.mit.edu/glossary/term/150 is
necessary, it must be requested by June 2, 2012, regardless of the end
date of the award. Grantees may still exercise their one-time,
grantee-approved no-cost extension as long as the period of performance
http://osp.mit.edu/glossary/term/160 with the extension does not
extend beyond September 30, 2013. However, if a Principal Investigator
requires an extension beyond September 30, 2013, he/she must seek a
waiver in accordance with the guidance below for “awards that are
scheduled to end after September 30, 2013.”

For awards that are scheduled to end AFTER September 30, 2013

Principal Investigators must contact their NSF Program Officer in
writing, with a copy of the Contract and Grant Officer in Sponsored
Projects, no later than March 2, 2012 and provide either 1) a plan to
accelerate completion of the project or 2) to request that a waiver be
sought for completion of the project as originally planned. The
criterion for a waiver is as follows:

* 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;

* 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).

NSF will review all submitted requests and determine whether they will
be included in the NSF’s waiver request to OMB.

Principal Investigators that have ARRA funded Career awards are not
required to provide a plan for accelerated spending or a request a
waiver. NSF will request a waiver for those awards.

NSF will amend awards to ensure that the period of performance does not
extend beyond September 30, 2013 in order to comply with the OMB
memorandum.

Sponsored Projects strongly encourages Principal Investigators to
responsibly accelerate spending on their ARRA awards to the greatest
extent possible because waivers are not guaranteed. While this guidance
applies to NSF and NIH awards, all federal agencies have been directed
to provide guidance. Guidance from other federal agencies will be
disseminated, via this listserv and the Sponsored Projects website, when
it is received.

If you should have any questions, please contact your Contract and Grant
Officer.

http://apps.research.uci.edu/orastaff/staff.cfm?view_department=spda
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