Reporting and Record Retention Guidance for NIH Grantees

NIH requires all Federal Financial Report (FFRs) (domestic and foreign) to be submitted using the electronic FFR system located in the eRA Commons. This includes all initial FFRs being prepared for submission and any revisions being submitted or re-submitted to NIH.

Foreign grantees must submit annual Federal Financial Report (FFRs) on Standard Form SF-269, in U.S. dollars, whether or not they are under Streamlined Noncompeting Award Process (SNAP). This is due to the fact that foreign grantees are not paid through the Payment Management System (PMS) and, therefore, do not submit the SF-272 (which the National Institutes of Health (NIH) uses in lieu of the annual FFR for domestic awards under SNAP). The currency rate in existence at the time the FFR is prepared should be used in preparing the report. Record retention requirements are the same as those for domestic grantees.

Grantees generally must retain financial and programmatic records, supporting documents, statistical records, and all other records that are required by the terms of a grant, or may reasonably be considered pertinent to a grant, for a period of three years from the date the annual FFR is submitted. For awards under SNAP (other than those to foreign organizations and Federal institutions), the 3-year retention period will be calculated from the date of the FFR for the entire competitive segment once submitted. Those grantees must retain the records pertinent to the entire competitive segment for three years from the date the FFR is submitted to NIH.

Foreign organizations and federal institutions are required to submit annual FFRs for all awards, including those under SNAP, and must retain these records for a period of three years from the date of submission of the annual FFR to NIH. See 45 Code of Federal Regulations (CFR) Section 74.53 - Retention and access requirements for records and 45 CFR Section 92.42 - Retention and access requirements for records for exceptions and qualifications to the 3-year retention requirement. Those sections also specify the retention period for other types of grant-related records, including F&A cost proposals and property records. See 45 CFR Section 74.48 - Contract provisions and 45 CFR Section 92.36 - Procurement for the record retention and access requirements for contracts under grants.

If you have a funded Fogarty grant or cooperative agreement and have questions about filling out the FFR form, please contact the appropriate person below at the NIH Office of Financial Management (OFM):

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