The National Institutes of Health through the Extramural Grants Management Advisory Committee (GMAC), and the Contract Management Advisory Committee (CMAC), has established policies and procedures to assure a consistent and integrated approach to oversight practices that monitor extramural grantee activities for NIH contracts, grants, and cooperative agreements. These committees meet approximately twice a month. Guidance for progress tracking, financial management, and administrative management of NIH grants includes OMB Circular A-110, OMB Circular A-123, Management's Responsibility for Internal Control, sections of the Recovery Act including Section 1512, and the Updated Implementing Guidance for the Recovery Act of 2009.
In addition, the NIH Office of Management Assessment (OMA) and the Office of Financial Management are establishing a common framework for identifying, assessing, and testing of operational and financial risks and internal controls associated with implementing Recovery Act requirements. OMA will work with NIH offices that are responsible for implementing programs receiving Recovery Act funding to: identify and score the Recovery Act risks, assess controls related to the identified the Recovery Act risks, remediate controls as needed, monitor the inventory of the Recovery Act risks, and report on the risks and controls to NIH and HHS leadership. These assessments will be done consistent with the statutory requirements of the Federal Manager’s Financial Integrity Act, which required managers to assess the effectiveness of management controls applicable to their responsibilities, and the Improper Payments Information Act, as well as OMB’s circular A-123 Management’s Responsibility for Internal Control, which strengthens financial management controls so that Federal agencies can better detect and prevent improper payments.
Progress reports are required for all active projects annually. The reports are reviewed by both program and grants management staff as required in the respective NIH Manual Chapters. The review process includes a project officer completing a review checklist for each project that covers: progress, scope, planning, any project changes, safety, outputs, and reporting requirement. The checklist requires additional information for any identified risk or challenge areas. Mitigating or corrective actions are documented and trigger additional review as required. Outputs are reviewed by program officials to confirm appropriate progress. Progress standards are based on planned activities and milestones within the grant application.
Grants management specialists monitor disbursements from the grantee project accounts as reported in the quarterly SF272 (Cash Transaction Report) to assure that the drawdowns from the Division of Payment Management System are appropriate for the effort described in the application. When disbursements are outside of planned parameters, grants management specialists contact the grantee for additional information, and confer with NIH program staff to determine whether the project may be at risk. Decisions to limit disbursements based on actual charges to the project may be required, if project funds are determined to be at risk. Additional funds may be withheld if progress is not satisfactory, and continued concerns may lead to suspension or termination of award.
NIH conducts technical assistance visits for oversight of grantee organizations when deemed necessary by the grants management specialist based on a GMAC Risk Assessment analysis. Site visits and reviews are tailored to the specific circumstance of use for each Grantee Institution, with the participation of grant and/or program management as needed.
Although science validates itself statistically, other forms of evaluations occur on a regular or as needed basis. The findings from evaluability assessments, evaluations and system assessments are used to improve or to eliminate activities.