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Learn about the different types of Award Action Requests (AAR) available in the Grants Online system, including No Cost Extension, Budget Reallocations, and changes in Key Personnel. Understand the general guidance and business rules for submitting AARs via Grants Online.
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References: • 2 CFR, Subtitle A, Chap. II, Part 200, Subpart D • 15 CFR, Part 24, Subtitle A, Subpart C & Subpart D, • Department of Commerce Grants and Cooperative Agreements Interim Manual • Department of Commerce Grants Online Manual
Types of AAR • Award Action Requests (AAR) • Grants Online provides the ability for Recipients to submit various different Award Action Requests. • No Cost Extension • Budget Reallocation • Change in Principal Investigator/Project Director • Key Personnel Changes • Change in Scope • Foreign Travel • Equipment Requests
General Guidance & Business Rules • Department of Commerce requires • All AARs must be submitted via Grants Online to include an official memorandum approved by the Recipient Organization’s authorized approving official: • Regional Association’s Director • Recipient Organization’s Research Director • Recipient Organization’s Grant Manager/Director • Submitted in Grants Online by the Recipient Authorized Representative. • Identified in the original proposal application’s SF424
No Cost Extension AAR • No Cost Extension (NCE) – Extension to Closeout • An extension to closeout may not be requested after the closeout period has expired. • An extension to the closeout period should only be requested to complete the preparation of final reports and make final payments. • Submit NCE AAR within 90 – 30 days prior to the project’s expiration date • Less than 30 days may result with not enough time for NOAA Grants Management Division to process the AAR in Grants Online • IOOS can only recommend approval • Final approval is at the discretion of NOAA Grants Management Division.
No Cost Extensions AAR • NCE AAR must include • Up to date project budget - SF424A • Provide the exact number of NCE months to include the proposed new close-out date (date/month/year) that is required to complete the project • A detailed reason why the project was not completed in time of the original close-out date: • Strong justification reasons are the following: • Unexpected key personnel loss • Complete final dissemination and financial close-out efforts • Disaster related delays (i.e. hurricane, major fires)
No Cost Extensions AAR • NCE AAR must not include • Specific conditions that prohibit the extension • The extension requires additional Federal funds • The extension involves any change in project objectives or scope of work • Specify that the project requires a NCE merely for the purpose of using unobligated funds
Budget Reallocation AAR • Budget Reallocation/Rebudget • Creation of a new direct cost line item category within an approved budget for costs allowable under the applicable cost principles will not require prior approval from the Grants Office unless the new direct cost category exceeds 10% of the total Federal share over the life of the award. • Transfers of funds among direct cost categories for awards in which the Federal share of the project is $150,000 or less will not require prior approval from the NOAA Grants Management Division. • Prior approvals are required in Grants Online for rebudget AAR that exceed 10% or transfers for Federal share of the project is over $150,000
Budget Reallocation AAR • Budget Reallocation/Rebudget AAR must include • An up to date SF424A • Show the total approved budget versus requested revision(s) • A detailed budget narrative explaining the funds transferred and identify the project’s direct cost budget categories. • A formal memorandum signed by the recipient organization’s authorized approving official • Budget Reallocation/Rebudget AAR must not include • Change and/or add project objectives or tasks that do not involve a transfer of funds between direct cost budget categories • Prohibited from expending award funds (Federal and/or non-Federal) or the Recipient’s provision of in-kind goods or services, for the purposes of providing transportation, travel, or any other expenses for any Federal employee unless specifically authorized in the award document.
Change in Key Personnel or PI AAR • Key Personnel or PI Changes • Recipient organization must request prior approval from IOOS for Key Personnel or PI/Project Director changes • Contact both IOOS’ Technical POC and Grants Specialist prior to submitting an AAR via Grants Online • IOOS only recommends approval. • NOAA Grants Management Division has the final determination for key personnel and PI changes.
Change in Key Personnel or PI AAR • Key Personnel or PI Changes must include • Formal memorandum signed by the recipient organization’s authorized approving official with detailed explanation for changes • Identify individual (add and/or removal) – Full name & title • Identify and describe project’s role • Reason for change • Effective date of change • New Key Personnel’s or PI’s current CV/Resume
Change in Scope AAR • Change in Scope AAR • The recipient organization may make changes in the methodology, approach, or other aspects of the project objectives. • The PI must make the initial determination of the significance of a change and should consult with their grantee organization as necessary. • Must obtain prior approval from IOOS for a change in the direction, type of research or training, or other areas that constitute a significant change from the aims, objectives, or purposes of the approved project. • Contact the IOOS technical POC prior to submitted the AAR in Grants Online
Change in Scope AAR • Change in Scope AAR must include • A formal memorandum with a detailed justification for the change in scope submitted in Grants Online and signed by the recipient organization’s authorized approving authority • An up to date SF424A • A detailed budget narrative describing the planned expenditure of the remaining funds • If a Change in Scope request includes a request for a no cost extension, then you must also submit a No Cost Extension AAR • IOOS can only recommend approval. • NOAA Grants Management Division has the final determination for key personnel and PI changes.
Foreign Travel AAR • Foreign Travel AAR • The Recipient shall comply with the provisions of the Fly America Act (49 USC § 40118). The implementing regulations of the Fly America Act are found at 41 CFR §§ 301-10.131 through 301-10.143. • The Fly America Act requires that Federal travelers and others performing U.S. Government-financed foreign air travel must use U.S. air carriers, to the extent that service by such carriers is available. • Refer also to the Department of Commerce Financial Assistance Standard Terms and Conditions. • Foreign air carriers may be used only in specific instances, such as when a U.S. air carrier is unavailable, or use of U.S. air carrier service will not accomplish the Agency's mission. • Use of foreign air carriers may also be used if bilateral or multilateral agreements permit such travel pursuant to 49 USC § 40118(b). • Information on current bilateral or multilateral agreements are found at http://www.gsa.gov/openskies
Foreign Travel AAR • If a foreign air carrier is anticipated to be used for travel and/or if foreign travel was not requested in the original proposal/revise work plan • Prior approval is required • Foreign Travel AAR must include • Formal memorandum with a justification for travel and/or use of a foreign air carrier signed by the recipient organization authorized approving authority • Travelers fullnames, title and reason for travel • Location and dates of travel • Full name of workshop/conference – No acronyms • Flight itinerary • Hotel and per diem rates
Equipment AAR • Equipment requests that were not identified in the original proposal • Prior approval is required • Equipment AAR must include • An up to date SF424A • A detailed budget narrative explaining equipment • Costs • Number of equipment • Project’s use for the equipment • A formal memorandum signed by the recipient organization’s authorized approving official • Vendor quotes are required for equipment over $10,000 • Must have sole source justification if there only one available vendor for equipment over $10,0000
Final AAR Thoughts • When in doubt with submitting an AAR contact IOOS Technical POC and Grants Specialist • Ensure that your recipient organization’s authorized approving official is fully aware and has approved requested changes that require an AAR • Grants Office/Department • Research Office • RA Director • REPEAT: When in doubt contact IOOS Technical POC and Grants Specialist