HHS PMS Subaccounts

The National Institutes of Health (NIH) has issued notice number NOT-OD-14-103 on 7/11/14 extending the timeline for  the Payment Management System (PMS) sub-accounting implementation deadline to October 1, 2015.  The notice is available at  http://grants.nih.gov/grants/guide/notice-files/NOT-OD-14-103.html.

In pursuit of strengthened fiscal oversight, all Department of Health and Human Services (HHS) operating divisions including the National Institutes of Health (NIH) are requiring changes in the method that all universities use to draw funds for sponsored research.

OSR/ASRSP/Cost Studies Staff Brownbag Presentation May 2014 (presented before implementation delay issued by NIH July 2014)

  • How Northwestern is currently paid
    • HHS grants are paid using the Payment Management System (PMS).
    • HHS authorizes NU to draw down funds electronically through a letter of credit (LOC).
    • NU incurs costs on awards, then requests reimbursement through PMS.
  • What is changing
    • The change is in how NU draws the money down
    • Current draws in PMS are “pooled”, meaning there is a single dollar amount request for all awards at the university (labeled “G” awards).
    • New draws will be via “subaccounts”, meaning each award will be drawn individually (labeled “P” awards). Each individual expenditure rate will be monitored by HHS agencies.
    • Due to change in type of draw: Universities will not be able to request funds after 90 days from the end date of the award.
  • Northwestern implementation timeline
    • New & competing continuation awards issued 10/1/2013 or later are being issued as subaccounts.
    • Non-competing continuations will transition to subaccounts on the new budget period start date between 10/1/15 and 9/30/16.
      • HHS agencies will issue new Notice of Grant Awards to transition to subaccounts.
      • Awards that are not scheduled for closing out will be closing.
  • Impact at Northwestern during transition
    Applies to both direct awards for HHS agencies and subcontracts issued to NU (incoming subcontracts)
    • ASRSP will close old NUFin chartstrings and OSR will open new chartstring as pre-spending accounts.
    • NU department must finalize expenses on the old chartstring.
    • NU department must direct new expenses to the new chartstring.
    • Deficits cannot be carried forward so pre-spending on new charstring will be important.
    • Unspent balances will be carried forward when allowed.
    • NU outgoing subcontracts to other institutions will close early and be reissued as new subcontracts. Timely FINAL subcontract invoices for the old chartstring are critical.
  • Ongoing Impact at Northwestern
    • For new NIH subaccount grants, NU will not have access to draw funds 90 days after the award end date.
    • All trailing expenses must be posted in the financial system early, 30-45 days after the end date, to allow time for ASRSP review and draw.
    • Individual award expenditure rates will be monitored by agencies. Expenses must be posted in a timely manner throughout the award lifecycle.
    • Certify Effort and reconcile with payroll/salary plan timely to prevent late cost transfers (journals).
    •  Timely budget reconciliation will be very important to avoid a potential loss of funding.
    • Communication with Grant and Contract Financial Administrator regarding closeout  will be key to successful close out.