The document, authored by Missy Peloso of the University of Pennsylvania's Office of Research Services and presented at the October 2013 COGR Meeting, outlines the institution’s preparations and procedures related to the NIH’s conversion to subaccount management for federal research awards. Previously, the university managed pooled drawdowns on a daily basis and submitted quarterly LOC (Letter of Credit) reports; however, the conversion necessitates a shift to more frequent, project-specific subaccount draws and continued quarterly reporting. The transition affects a considerable volume of funding, with 460 non-competing continuations (NCC) totaling $230 million and an estimated $81.8 million in new awards projected for the upcoming fiscal year.
The presentation highlights operational challenges, such as increased administrative workload for both NSF and NIH awards, difficulties in finalizing drawdowns, timing issues related to award updates, and challenges in requesting advance draws leading to sizeable accounts receivable balances at month-end. To facilitate compliance, the university is adjusting project end dates, revising reporting deadlines, updating terms on award notices, and modifying internal records and fund/account structures to align with LOC transaction requirements. These measures are intended to ensure accurate tracking and management of funds under the new subaccounting rules, while maintaining regulatory compliance and supporting effective stewardship of federal research awards.
