NIH Modular Grants Under the Blanket Waiver for Grants/Subcontractors

NIH Modular Grants Under the Blanket Waiver for Grants/Subcontractors

NIH Modular Grants under the Blanket Waiver for Grants/Subcontractors

Requirements Grant Subcontractor Blanket Waiver

The UMDNJ policy for processing procurements under the Blanket Waiver for Grant/subcontractors requires the following information:

  1. A copy of SF424 grant application package: The grant application must specifically identify the subcontractor, equipment, supplies and/or other product with the associated costs (estimated is acceptable provided the estimate is close to the actual cost).
  2. Award notice: Grant has to be approved and approval documented.
  3. Completed GAFA
  4. When it applies, (vendor spending over $17,500 in fiscal year or over course of vendor’s contract with the UMDNJ school), submission of all State required compliance documentation[1]. Compliance requirements are uniform for all UMDNJ procurements.

NIH Modular Grants

NIH Modular Grants - The Modular Grant concept establishes specific modules or increments in which direct costs must be requested, as well as a maximum level for requested budgets of $250,000 direct costs (excluding any consortium F&A costs) per year. The Modular Grant application does not require a categorical breakdown of direct costs requested in the application; however, other requirements still apply. Application directions should be reviewed for specific modular instructions.

Detailed or itemized budgets are not required by NIH funding agencies for the submission of a modular grant application, with the exception of Personnel justification. . UMDNJ requires a detailed budget and justification from principal investigators for purposes of determining exclusions from the base when calculating facilities and administrative (indirect) costs and to ensure that adequate resources are being requested for the proposed research activity. However, any budgetary details required by UMDNJ are for its internal use ONLY and are NOT submitted to sponsor with the grant application.

Thus, the grant documentation submitted to the NIH will not have detailed budgetary information for project specific equipment, reagents, and/or other research supplies needed to perform the grant research project. Instead, these items, along with the associated cost of each item, should be identified in the detailed or itemized budget developed as part of the internal processing of the NIH grant application within UMDNJ. (See attachment for example of the internal NIH modular budget required at UMDNJ.)

For a NIH modular grant subcontractor to qualify under the blanket waiver for grant/subcontractors, the principal investigator and/or institution/school will submit to the Purchasing Services Department with the requisition in Marketplace the following documentation:

a. NIH Grant Application – SF424 package will include modular budget pages

b. Grant approval letter or e-mail from NIH – Award notice

c. Completed GAFA

d. The internal budget prepared by the principal investigator and submitted to the Office of Research and Sponsored Programs (“ORSP”) and Grants and Contracts as part of the UMDNJ internal grant approval process.

  1. This document is dated to assure it was submitted as part of the internal UMDNJ grant approval process or:
  2. The institution will provide evidence (i.e., e-mail affirmation or stamp dated pages coinciding with GAFA approval signatures) to Purchasing Services on the date of submission of the document in the internal UMDNJ grant approval process.

Amendments or Changes to NIH Modular Grant Budgets.

Changes or amendments to budgets under NIH modular grants do not require approved by NIH. Under NIH governing rules, the NIH delegates the authority for review and approval of changes to the institution applying for and administering the grant under expanded authority[2]. In this instance, the principal investigator will submit an amended budget explaining the reason(s) for the change to the Business Official in Grants and Contracts and the Institutional Signing Official or Research Dean in ORSP. It is understood that the investigator has researched into the best purchase option, with competing quotes when applicable. The amended budget will provide for the same specificity on the new proposed subcontractor, equipment or product and associated cost for each item that is required under the detailed internal budget prepared by the principal investigator for the original NIH grant application. The designated authority at the institution will approve or disapprove the requested budget amendment. To process the procurement in these circumstances under the blanket waiver for grant/subcontractors, the principal investigator or institution shall file the following documents with the requisition in Marketplace:

  1. NIH Grant Application (if not already on file)
  2. Grant Award Notice ( if not already on file)
  3. Completed GAFA (if not already on file)
  1. Internal administrative approval of the budgetary change.

[1] State compliance documents are usually valid for at least a two (2) year period from date of compliance.

[2] The NIH grant approval will explicitly indicate under what conditions the grantee institution does not have the authority to approve such changes (i.e. outside of scientific scope, over 25% change of total award, etc.). Under NIH policy, for modular grants, the authority is implicitly granted unless otherwise explicitly withheld in the grant approval letter.