The following answers to frequently asked questions address questions about Fogarty and/or foreign awards.
Applying and Reporting
Which assurances and public policy requirements are applicable to foreign institutions?
Section II.B.16 of the NIH Grants Policy Statement provides detailed information about assurances and Public Policy Requirements and Objectives as they relate to foreign organizations.
Also, Section II.A.4 of the NIH Grants Policy Statement provides a complete list of Public Policy Requirements, Objectives, and Other Appropriation Mandates as they relate to all institutions (foreign and domestic).
Examples include but are not limited to:
- Research Misconduct
- Animal Welfare
- Human Subjects
- Financial Conflict of Interest
- Inclusiveness in Research Design
- Debarment and Suspension
May foreign institutions submit modular budgets?
No. The detailed budget format is required for foreign institutions to allow NIH staff to assist with applicable regulatory and policy requirements for grant funding expenditures; therefore, modular budgets are not allowed from foreign institutions. However, domestic institutions with a foreign subcontract may use the modular budget format.
The NIH Grants Policy Statement discusses application procedures relevant to Grants to Foreign Institutions and to Modular Applications and Awards.
Are Federal Financial Reports (FFRs) required annually for SNAP awards to foreign institutions?
Yes. Federal Financial Reports (FFRs), formally called Financial Status Reports (FSRs), must be submitted annually via eRA Commons by all foreign grantees, even if the foreign award is a SNAP award.
The person assigned the FFR/FSR role in eRA Commons will see the FFR/FSR tab and may complete the report or delegate it. For Instructions on how to assign someone the FFR/FSR role, view the eRA Commons Frequently Asked Questions (FAQs).
FFRs are due 90 days after the end of the calendar quarter in which the budget period ends.
More information is available in the NIH Guide Notice NOT-OD-11-017 Implementation of Federal Financial Report - Upcoming Mandatory Use of the Federal Financial Report System in the eRA Commons Beginning February 1, 2011.
What information do I need to include in the progress report for my Fogarty grant?
Fogarty provides detailed supplemental guidance for completing progress reports specific to Fogarty grantees, including guidance for SNAP and non-SNAP awards, and for the electronic federal Research Performance Progress Report (RPPR) and paper PHS 2590 progress reports.
Is the Responsible Conduct Research (RCR) policy applicable to foreign institutions?
Yes. The Responsible Conduct Research (RCR) policy is applicable to all projects that require instruction in responsible conduct of research as noted in the Funding Opportunity Announcement, whether domestic or foreign. For more information refer to the NIH Notice OD-10-019 Update on the Requirement for Instruction in the Responsible Conduct of Research.
How do foreign institutions receive grant funds?
Awards to foreign institutions and international organizations issued prior to October 1, 2012 are normally paid by U.S. Treasury check by the NIH Office of Financial Management on a predetermined quarterly advance basis, usually in four equal installments. The contact person at OFM responsible for these payments is Ms. Jennifer Rock, who may be reached at firstname.lastname@example.org or 301-402-9171.
Awards to foreign institutions and international organizations issued after October 1, 2012 are paid through the Payment Management System (PMS). The contact person at PMS responsible for these payments is Ms. Raynette Robinson, who may be reached at email@example.com or 301-492-4938.
How should domestic grantees pay foreign consortium or subcontract costs?
Many foreign institutions have unique fiscal needs and/or may not have the infrastructure to pay award costs prior to receiving grant funds. Therefore, it may be reasonable for U.S. grantee institutions with a foreign consortium to provide the foreign institution quarterly advances of funds or arrange a reasonable payment schedule to accomplish the goals of the NIH grant. Ultimately, payment arrangements are subject to the grantee's institutional policies and should be clearly defined in the Consortium Agreement.
May funding requests be made in foreign currency and then be converted to U.S. Dollars?
No. All requests for Funding and Payment, including the budget contained in the application, must be stated in U.S. Dollars. Once an award is made, the NIH will not compensate foreign grantees for currency exchange fluctuations through the issuance of supplemental awards.
Do foreign institutions have to negotiate a Facilities and Administrative (F&A) cost rate agreement with NIH to receive F&A costs of up to eight percent of the total direct costs (less equipment)?
No. Foreign institutions do not need to negotiate an F&A rate. Technically, Reimbursement of Facilities and Administrative (F&A) Costs is not allowed for foreign institutions. Instead, a flat eight percent rate (exclusive of equipment) is allowed in order to help defray the cost of compliance with NIH policies. NIH refers to the eight percent rate as F&A. Refer to the NIH Grants Policy Statement for more information about Allowable and Unallowable Costs for foreign institutions.
What do grantees do with interest earned on grant funds?
All grantees are required to maintain advances of grant funds in an interest bearing account.
The Funding and Payment policy as it applies to foreign institutions is that interest earned in excess of $250 USD per year in the aggregate on advances of Federal funds must be returned by reimbursement check to the NIH Office of Financial Management (OFM), and reflected on the annual Federal Financial Report (FFR).
Refer to the NIH Grants Policy Statement for the general policy on Interest Earned on Advances of Grants Funds, regardless of foreign or domestic status.
What is program income?
Program income is gross income earned by a grantee, a consortium participant, or a contractor under a grant that was directly generated by the grant-supported activity or earned as a result of the award. Refer to the NIH Grants Policy Statement for more details about Program Income.
Do I need NIH prior approval for all budget or project changes no matter how minor?
No. Only certain changes in project and budget require NIH prior approval. Other changes should be handled internally according to the grantee institution's policies and procedures.
Foreign institutions are subject to the same administrative requirements regarding changes in project and budget as domestic grantees.
What is the NIH policy concerning the transfer of a grant to or between foreign institutions?
All requests for changes of grantee organizations require NIH prior approval regardless of whether the institutions involved are foreign or domestic.
A change of grantee organization that involves the transfer of a grant to or between foreign institutions or international organizations requires approval by the appropriate NIH Institute or Center's Grants Management Officer and approval of the Institute or Center's Advisory Council/Board.
A change of grantee organization that involves the transfer of a grant from a foreign organization to a domestic organization requires only the approval of the Grants Management Officer.
Is NIH prior approval required for adding a new foreign consortium or subcontract to a project?
Yes. Adding a new foreign consortium or subcontract always requires prior approval. Refer to the NIH Grants Policy Statement for more details about the Transfer of the Performance of Substantive Programmatic Work to a Third Party by Means of a Consortium Agreement.
May a grant with multiple Principal Investigators (PIs) be changed to a single PI?
Yes. In rare cases and with appropriate justification, a request to change from multiple PIs to a single PI (or vice versa) may be approved. The NIH Grants Policy Statement offers more information about Multiple Program Direct/Principle Investigator Applications and Awards.
The NIH Office of Extramural Research (OER) offers more information on the Multiple Principal Investigators policy page.