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Hi, Just a quick update on the federal shutdown.


·         As stated last week, NIH and NSF are not accepting proposals at this time.   We anticipate that deadlines will be adjusted once the agencies reopen.   Until that time, we strongly advise not to submit to grants.gov for NIH and NSF.  Other agencies may be accepting applications.  Please consult with your OSP Grants Officer.   Once NIH and NSF reopen, please be prepared to identify correct new deadlines and respond accordingly.


·         Please feel free to start proposals in Rapport.   Please note that the team is working on a patch to correct bugs and make additional mechanisms (e.g. K award) available in relation to the new NIH Forms C.   We are hopeful to test and deploy this in the next week and a half.


·         Please alert OSP if you receive any stopwork orders on contracts.


·         Check the OSP website for updates.  Please share with me any news that you feel would of general interest to your colleagues.


___________________________________________________________________________________________________________________________________
This from the Council on Government Relations, a consortium of Universities and Colleges


Research Administration and Compliance Under Federal Government Shutdown

At the writing of this Update, an end to the Federal Government Shutdown remains unresolved. Many of your institutions are now experiencing the effects of the shutdown through selected interruptions or stoppages in research activities, financial and cash management repercussions, and other consequences related to the shutdown. Some recent challenges that your institutions have shared with COGR include:

 Denied reimbursement by the Payment Management System (PMS), even though NIH indicated in their guidance that PMS would be available except in situations that required manual intervention by agency staff.
 Treatment of university faculty and employees working under an Intergovernmental Personnel Act (IPA) Agreement as furloughed federal employees.
 Management of subrecipient agreements as the shutdown continues.

This list is growing. The “Agency Contingency Plans” posted on the OMB website (see below), while helpful, do not anticipate every challenge or issue.
http://www.whitehouse.gov/omb/contingency-plans

The analysis below is a resource to help navigate research administration and compliance activities during the shutdown – but again, as the shutdown continues, unanticipated challenges will develop.


·         The principal Federal agencies supporting research have issued notices outlining policy and system issues during the Federal government shutdown.


·         The National Institutes of Health notice (NOT-OD-13-126) is available at the still accessible but not updated website at: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13-126.html.


·         As you know the National Science Foundation’s website is not available but NSF’s guidance to grantees appears at: www.nsf.gov<http://www.nsf.gov>.


·         Applications: Both agencies, NIH and NSF, will announce new deadline or target dates for programs with deadlines during the shutdown as soon as government operations resume. Submission through Grants.gov, which is available during the shutdown, seems unwise as the agencies will not be downloading applications to Fastlane or the eRA systems until the resumption of operations. The checks for compliance or confirmation of receipt will not occur and the potential back-log could create its own set of problems.


·         Reviews: Panels and study sections have been canceled and will be rescheduled as the agencies open for business.


·         Awards: All new awards or new increments have been halted. NIH notes that “for any awards processed before the funding lapse that have an issue date during the funding lapse, the awards will not be sent to the grantee on the issue date. Once operations resume, all pending NoAs will be sent. This will not affect the start date nor the issue date of these awards; it just affects the date the award document is actually sent to the grantee and available for access in the eRA Commons. In the absence of actually receiving the NoA, institutions may use pre-award costs authority at their own risk.”


·         Performance: If an institution has a current award, all work and activities performed under currently active awards can continue to the extent that funds are available (e.g., within the currently approved budget).


·         Reporting: Because the electronic systems used for reporting, eRA Commons and Fastlane, are not available, various reports – progress, project, etc. – cannot be submitted. Nor will requests be acknowledged or responded to, e.g., no-cost extension, close-outs, etc.


·         Regulatory Compliance: In general, the institution’s responsibilities for meeting its compliance obligations – protection of human subjects, care and use of animals, review and determination of financial conflicts of interest, inquiries and investigations of research misconduct, training in the responsible conduct of research, etc. (it’s a long list) – remain the same. There is no shutdown or lapse in an institution’s responsibilities; those responsibilities and requirements are on-going. Compliance and oversight staff will not be available for consultation and the systems used for reporting are not available. Emergencies related to human subjects protections under NIH awards should be reported to NIH Deputy Director Sally Rockey, (see NIH notice for contact information).


·         Other Agencies: The impact of the shutdown on operations across agencies is not consistent.  For example, those agencies and offices with sources of revenue outside the Federal appropriations process – the collection of fees for services – remain open and operating, e.g., the Patent and Trademark office. The length of the shutdown has resulted in changes in operation during the shutdown itself. The Centers for Disease Control and Prevention brought some workers back to address a recent salmonella outbreak, and the Department of Defense will bring back most of its civilian work force based on the reading of the law that allows the DOD to eliminate furloughs for employees whose responsibilities contribute to the morale, well-being, capabilities and readiness of service members. This change in DOD staffing can have a direct impact on the research enterprise. The Congressionally Directed Medical Research Program (CDMRP) program deadlines have not been changed and its eReceipt system including the help desk remains available for submissions. The website site acknowledges “actions related to existing funded grants are likely to experience some delay.”


·         Other agencies will have implemented different policies for management during the shutdown. It is wise to check whether the agency you NEED to reach is available.



Jill M. Mortali
Director
Office of Sponsored Projects
Dartmouth College
11 Rope Ferry Road
Hanover, NH 03755
603-646-0678


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