HHS PMS Subaccounts

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. As a result of these changes, a set of Northwestern awards will be terminated earlier than anticipated and transition to new awards for the remaining years.

 HHS PMS Subaccounts FAQs

  • How Northwestern is currently paid
    • HHS grants are paid using the Payment Management System (PMS).
    • HHS authorizes Northwestern 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 Northwestern 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 award expenditure rate will be monitored by HHS agencies.
    • Due to change in type of draw: Northwestern will not be able to request funds after 90 days from the end date of the award without a separate sponsor review and approval process.
  • NIH 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.
    • On 5/28/2015, NIH issued a reminder notice reiterating this timeline.
  • AHRQ, HRSA, and CDC implementation timeline
    • HHS operating divisions Agency for Healthcare Research and Quality (AHRQ), Health Resources and Services Administration (HRSA) and Centers for Disease Control (CDC) have an earlier implementation timeline that NIH.
    • 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 10/1/14 and 9/30/15.
      • 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 Northwestern (incoming subcontracts)
    • ASRSP will close old NUFinancials chart strings and OSR will open new chart string as pre-spending accounts.
    • Northwestern department must finalize expenses on the old chart string.
    • Northwestern department must direct new expenses to the new chart string.
    • Deficits cannot be carried forward so pre-spending on new chart string will be important.
    • Unspent balances will be carried forward when allowed.
  • Ongoing Impact at Northwestern
    • For new NIH subaccount grants, Northwestern will not have access to draw funds 90 days after the award end date without a separate sponsor review and approval process.
    • 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 LOC 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.

If you have additional questions, please email PMS Subaccount Transition at Northwestern.