Megan Columbus: Welcome to another addition of All About Grants, this is Megan Columbus from NIH’s Office of Extramural Research. You know a couple of months ago we did a podcast that was a general overview of the three reports required for close out. Today we have with us Renee Livshin, who is a grants management specialist with NIH’s National Heart, Lung and Blood Institute. She is going to delve more deeply into how the pieces of the FFR reconcile and the implications for you as a grantee. This topic will be of interest to those of you who are responsible for the accounting and financial aspects of a grant award, and remember for a small business this may indeed be the PI. You know, the FFR is relatively new to NIH; could you describe what the pieces of the report are?
Renee Livshin: Yes, the FFR was put into place February 2011, and it’s comprised of the expenditure data report and the cash transaction report.
Megan: So let’s start with expenditure data report. For those of you who have been with NIH for a long time, this used to be called something else. What was that?
Renee: This used to be the financial status report, formerly the SF 269.
Megan: Okay and how is this piece of the FFR submitted.
Renee: This piece is submitted through the eRA Commons with a user that has the FSR role.
Megan: Okay and the FSR role is just a legacy to the old form, so that name I’m sure at some point will change. Are there particular things that people need to be paying attention to when they’re submitting this report?
Renee: Yes, as Michelle Bulls mentioned in a previous podcast, this final FFR expenditure report needs to include a final unobligated balance, the expenditures, and no un-liquidated balances should be reported.
Megan: And the timing for submitting it?
Renee: The timing for this report is 90 days after the end of the project period.
Megan: So if people have problems submitting, technically they should be contacting the eRA help desk. What about if they have more substantive questions about the report?
Renee: The Office of Financial Management is a great resource for submitting, for questions regarding the data elements of this report.
Megan: So should people ever be contacting the grants management specialist about this or really, it’s just the office of financial management?
Renee: They can contact their grants management specialist if they have questions regarding the authorized amounts.
Megan: Okay, let’s talk about the cash transaction report piece. So this again used to be something else, which was…
Renee: This was formerly the SF 272.
Megan: Okay and so this cash transaction report is submitted not through the Commons but through…?
Renee: It’s submitted through the Payment Management System.
Megan: And when does it get submitted?
Renee: This report is submitted 30 days after the quarter ends, as opposed to the 45 days with the previous report,
Megan: So Renee, my understanding is that working with the Payment Management System, it can sometimes be a little bit confusing about what’s getting reported and how you’re drawing down; can you explain that a little bit?
Renee: Sure, some confusion arises with this reporting because the grantee institutions are, when they’re charging and drawing down funds, they are doing a pool draw down. And when they are reporting disbursements on the cash transaction report, they are reporting on a grant-by-grant basis, and this sometimes causes some confusion.
Megan: Any tips for how they can keep it straight?
Renee: Just having the proper accounting systems in place so that they can see exactly what is being spent on each grant.
Megan: There’s two pieces of this report coming into separate systems at separate times potentially submitted by separate people at your institution. What are the implications, I can imagine there is a risk there because I believe that on our side the systems don’t talk to each other quite yet. So what are the implications of the grantee not being careful about reconciling the expenditures and disbursement between those two reports?
Renee: The grantee may be placed in a deficit situation, owing the federal government directly, and personal liability may also be incurred. And the NIH will not restore funds if the grantee is placed in a deficit situation. It is really important to make sure that your disbursements match your expenditures in both of the systems.
Megan: So that clearly is important. What happens for that cash transaction report if it’s not submitted at all?
Renee: If there are charges, also known as drawdowns under a particular grant, and there are no disbursements reported, the grantee will owe the federal government the amount that was charged because it appeared that they never reported these funds as spent.
Megan: So if people are having trouble, then, submitting that cash transaction report, you know, who should they be talking to?
Renee: They should be taking to their Payment Management System account representative, and they can also let them know that it’s really important that their reports reconcile and they can tell them what specifically their expenditures are and they should be able to help them with reporting their disbursements.
Megan: Okay, so clearly it’s important for folks to reconcile these reports
Renee: It’s very important.
Megan: Before we go any parting advice?
Renee: Yes, there are great user guides that are references: one for the expenditures data report that is found on the era.nih.gov website, and a user guide for the cash transaction report that which is found on the payment management system website.
Megan: Wonderful, thank you Renee. For NIH and OER, this is Megan Columbus.