This document, presented by Michelle G. Bulls, Director of the Office of Policy for Extramural Research Administration at the NIH, provides an overview of significant updates to grant administration policies following the implementation of 45 CFR Part 75 and related government-wide regulations. The presentation outlines the development of a Research Terms and Conditions (RTC) Overlay document, intended to offer additional clarity on select provisions consistent with federal research policy. Until the RTC Overlay is finalized, NIH and other federal agencies have introduced their own interim terms and conditions to guide grant management. For NIH, this includes a revised Notice of Award (NoA) format and updated General Grant Conditions effective for awards issued on or after December 26, 2014. The updates bring NIH policy and documentation into alignment with new federal requirements, including the adoption of uniform administrative requirements, cost principles, and audit standards.
Key procedural changes covered in the document include expanded flexibilities for grantees, such as the ability to rebudget funds, initiate no-cost extensions, and directly charge certain costs without prior NIH approval, provided these do not constitute a change in scope. The document also details revised requirements for final reporting and the implementation timelines for new procurement standards, with transitional provisions for academic and nonprofit institutions. Answers to anticipated questions clarify that although the RTC formal approval timeline is uncertain, NIH will apply the new terms retroactively to awards made on or after December 26, 2014, and has taken steps to reduce administrative burden and increase flexibility for grantees. The NIH is committed to ongoing coordination with other agencies and timely communication of further policy updates.
