May 4, 1992
Subject: Public Health Service Grant Application Kits PHS 398 (Rev. 9/91) and PHS 2590 (Rev. 9/91)
The Public Health Service has distributed copies of its revised Grant Application Kit, PHS 398, dated 9/91 and Continuation of a Grant Award, PHS 2590, also dated 9/91. Campuses are now in the process of providing department staff with clarifications of the PHS instructions and additional campus requirements for completing these applications. The purpose of this memo is to provide a summary of the more important changes from the previous PHS application kits, dated 10/88, and clarifications of the PHS instructions as they were explained to RAO staff by National Institutes of Health Grants Policy staff.
GRANT APPLICATION FORM PHS 398
Several campus Contract and Grant Officers as well as Research Administration Office staff have discussed the revised application with staff at the National Institutes of Health (NIH) Grants Policy Office. While there are many changes in the 9/91 Grants Application Form PHS 398 from the previous version, dated 10/88, most of them are clear. They include changes in the number of required copies, add facsimile and electronic mail numbers, increase the research plan page limit, change the appendix limitations, and provide additional instructional information.
NIH is preparing a "question and answer" guide to clarify issues raised by applicant institutions in response to the PHS kit. This additional NIH information should be published in the NIH Guide within the month.
IV. PREPARATION OF THE APPLICATION
Page 9 - Computer-generated facsimiles of the forms in the application packet must be absolutely identical to the PHS printed form. This includes providing the exact spacing and every word found on the PHS form.
We have had some discussion with various campus Contract and Grant Officers about exchange of documentation templates and data entry screens and/or macros that could be used to generate electronic versions of the PHS 398 and 2590 forms as well as simplify budget preparation. If there is any interest in learning what campus departments have developed in this regard, which they are willing to share, RAO can facilitate the networking of what is available.
Form Page 2
Page 16 - The revised application now requires the social security number and date of birth for all personnel "at the applicant organization or elsewhere." While it is clearly stated on page 11 that "provision of the social security number is voluntary," no such option is described for the date of birth requirement.
OP RAO and campus C& G staff received conflicting information from NIH about providing the date of birth. The date of birth was requested in the previous application for key personnel only. NIH says it is used to track the number of awards going to "young investigators." However, requiring the date of birth for all personnel may not be legal. While NIH staff informed one campus that it is optional, OP RAO was advised that it should be provided unless there is an objection to providing it. When it is not provided, NIH may request it at a later date.
The second area of confusion with Form Page 2 is the difference between the instructions on the form page itself and those on page 16. The form page says to list "all individuals participating in the project." The instructions on page 16 adds the phrase "who will participate in the scientific execution of the project..." NIH staff has stated at all personnel must be listed on Form Page 2, meaning everyone listed on the budget under Personnel.
Page 19 - All other support, whether grants, contracts, gifts, prizes, or any other source of funds, which can be traced to the Principal Investigator or any other Key Personnel and is used in direct support of their research, must be reported. A separate Form Page 7 should be used for each entry. Additional NIH guidance on this subject will clarify that the agency does not want every general gift or prize reported. It is interested in those gifts which are directed to support of specific research, not just the investigator's general subject area. PHS will look at this information for conflict of interest and budgetary and scientific overlap.
Gender and Minority Inclusion
Page 21 - The most recent revision of the NIH/ADAMHA policy on inclusion of women and minorities in studies involving human subjects has been included. This revision should be published soon in an NIH Guide for Grants and Contracts.
Human Subjects and Vertebrate Animals
Pages 22 and 23 - If human subjects or animal subjects approval is pending, check "YES" in Sections 4a. or 5a. on the face page and enter "pending" in the box labeled IRB or IACUC "approval date."
Page 31 - The Age Discrimination Form HHS 680 listed on the Checklist is a new assurance which must be filed by each campus in accordance with the instructions on the form, on a one-time basis. A copy of all the DHHS assurances is enclosed for your information. Only the Age Discrimination Form HHS 680 needs to be filed with the DHHS Office of Civil Rights. The other three forms have been filed previously.
The OP Affirmative Action Office has reviewed the form and has determined that it can be signed by a campus Contract and Grant Officer with delegation of authority to sign assurances. Discrimination of the basis of age is prohibited under the University's Nondiscrimination Statement.
RESEARCH CAREER DEVELOPMENT AWARD AND INSTITUTIONAL NATIONAL RESEARCH SERVICE AWARD --
Indirect Cost Calculation
The information about how to calculate indirect costs on the Research Career Development Award (page 4) and the Institutional National Research Service Award (page 6) is not correct. The PHS Grants Policy Statement (pages 7-17 and 7-18) and the NIH Guide for Grants and Contracts contain the applicable policy guidance on how to calculate indirect costs for these two programs. (Copies attached.)
The March 20, 1992 NIH Guide for Grants and contracts (page
16) provides the most accurate and recent description of how overhead should be calculated on National Research Service Award (NRSA) Institutional Research Training Grants. It states that:
an indirect cost allowance based on 8 percent of total allowable direct costs exclusive of tuition, fees, health insurance, and expenditures for equipment, or actual indirect costs, which ever is less, may be requested.
For Research Career Development Awards, (RCDA) the PHS Grants Policy Statement provides that indirect costs:
will be reimbursed at 8 percent of total allowable direct costs, excluding the items in i above, or at the actual indirect cost rate, whichever results in a lesser dollar amount.
Thus, for RCDA and NRSA grants, overhead should be calculated both ways to determine which produces the lower dollar amount.
Historically, campuses have used the 8 percent rate. When stipends ware included in the base of the calculation (until 1988), the 8 percent rate yielded-a lower dollar amount. However, since stipends have been excluded from the indirect cost base, the campus' approved indirect cost rate may now yield a lower dollar amount.
Applicable Indirect Cost Rate for NRSA Training Grants
Whether the campus research rate or instructional rate is used to determine the applicable overhead depends on the function code applied to the grant. If function code for instruction and training is used, then the instructional and departmental research indirect cost rate should be applied. If function code "44", research, is used, the sponsored research rate should be applied. The campus Contract and Grant Officer should consult with the campus Indirect Cost Rate Coordinator and the Accounting Office in assigning the correct function code.
CONTINUATION OF A GRANT AWARD FORM PHS 2590
While the new Form 2590 for Continuation of a Grant Award is available for use, the NIH Grants Policy Office staff has stated that only the revised face page must be used at this point. Campuses may use up any remaining copies they have of the old Form 2590 until NIH publishes official guidance to use the new form.
Instructions for submitting the Form 2590 under the Federal Demonstration Project remain the same as those published in Contract and Grant Operating Guidance Memo No. 90-16, dated October 25, 1990. The progress report and the face page are required for all continuation applications. The Detailed Budget, Budget Justification, Biographical Sketch (for all new key personnel), and Other Support pages are required only if there are changes in these areas from the original proposal. The Checklist is not required.
For any of the sections in the revised Form 2590 which do have to be submitted, the guidance outlined above for the Form 398 applies.
REVIEW OF NEW ADMINISTRATIVE BURDEN
With the changes described above, Principal Investigators are reporting an increased administrative burden and more paperwork in completing the revised applications. In order for both of these application kits to receive required Office of Management and Budget (OMB) approval, the Public Health Service had to submit to OMB information which included the PHS estimates of the additional paperwork burden which would be incurred by the changes in these applications. The OP Research Administration Office has requested copies of these estimates from OMB and would like to compare them with actual time now being spent on completing the revised applications. If you have any information in this regard, please forward it to Samuela Evans in OP RAO. Principal Investigators who want to submit comments on the revised applications can direct them to the National Institutes of Health Program Directors with whom they work and the NIH Grants Policy Office.
Refer: Samuela A. Evans (510) 987-9S49
cc: Accounting Officers
Subject Index: 02, 08
Organization Index: F-350
David F. Mears