In 2014 NIH announced they would transition the manner in which payments are made for awards. For NIH domestic awards, payments have previously been requested and received using pooled accounts in the Payment Management System (PMS), which is the centralized grants payment and cash management system operated by the Division of Payment Management (DPM) under the Department of Health and Human Services.
Under the new subaccount method, requests for payments will be required based on actual expenses incurred on an award-by-award basis. As of October 1, 2015, NIH will utilize only subaccounts for awarding grant funds. The transition is expected to be completed by September 30, 2016.
For awards that receive new funding during the transition period, MIT will be required to submit a Subaccount Transitional Final Financial Report (FFR). The FFR enables NIH to end the grant’s association with the pooled PMS payment account and transition award payments to the PMS subaccount established for the grant, including transferring any carryover funds and unliquidated obligations remaining in the pooled account.
Managing the transition to subaccounts for the 153 currently active NIH awards requires that MIT take additional administrative steps. We will:
Create a New Subaccount Child
- When an award notice notes that funds will use a subaccount, OSP will create a new child account (“Subaccount Child”) that corresponds to funds provided under NIH’s new subaccounts.
- If needed, OSP will create a new cost-sharing child account associated with the new Subaccount Child. The DLC will need to submit a cost share template as needed.
- If needed, OSP will create a new subaward child account and move the subaward PO to the new subaward child account number.
Close-out the Parent
- VPF and DLC will close-out the active pooled account and submit an FFR for the “pre-transition” period to NIH. Note that 19 of the 153 accounts are fellowships that do not require FFRs.
- OSP will keep the existing Obligated End date on the parent account and keep it in Active status until notified by VPF that the closeout process is complete. OSP will extend the Anticipated End date to match the Anticipated End date on the Subaccount Child.
- If funds remain in the parent after closeout, VPF will carry forward funds to the new Subaccount Child.
- If the parent account is overrun, VPF will enter an RPO (Record Project Overrun) on the parent account, debiting the Subaccount Child and crediting the parent with the exact amount of the overrun.
- VPF will close-out any cost-sharing child account that is associated with the parent account.
- VPF will close-out any subaward child account that is associated with the parent account.
- Once closeout is complete, VPF will notify OSP (cc’ing DLC) to change the account status to Term Code 2 (Restricted) and to extend the Obligated End Date on the parent account to match the Obligated End Date on the Subaccount Child.
OSP will begin creating new Subaccount Child accounts to facilitate this transition. DLCs will need to work closely with VPF and OSP to ensure that all steps in the process are completed.