For questions related to the Federal Transition, please visit the Office of the Vice Chancellor for Research

POST AWARD

New NIH Guidance for First Time NCE Requests

NIH has announced as of 5-7-2025 that they have temporarily disabled the NCE functionality that exists for a first time No Cost Extension request.

We will now have to request as a prior approval request, like what is normally expected for a 2nd No Cost Extension request. Note this will require more lead time with OGC as we will now need to provide documentation and work with the GMS directly. If you have an outstanding request in place with us, we will reach out for more information, you can also go ahead to start to prepare the documents needed for the request.

Please see the OGC website for guidance on 2nd NIH extensions for more information about what is needed as this process will now apply to all NIH NCE requests. 

The full text of the NIH Guidance can be found via the NIH website. Please reach out to OGC.Postaward@ucdenver.edu for any added questions you may have.

HHS Federal Letter of Credit Payment Request and Changing Landscape

The Office of Grants and Contracts is working to navigate ongoing changes being made to our Letter of Credit Payment Request process for HHS.

Within HHS we draw for multiple agencies:

• National Institutes of Health (NIH) and all agencies
• Agency for Healthcare Research and Quality (AHRQ)
• Health Resources and Services Administration (HRSA) and its subagencies to include (Maternal and Child Health Bureau (MCHB)
• Substance Abuse and Mental Health Services Administration (SAMSHA)
• Administration for Community Living (ACL)
• Administration for Children and Families (ACF)
• Bureau of Healthcare Workforce (BHP)
• Centers for Disease Control (CDC)

We are now required to provide a justification for each award we are drawing for in a mandatory 1,000-character comment field.  If further clarification is required, we will receive an email from “Defend the Spend” which will require we submit additional details via a link to the doge.gov website.

Two of the agencies, ACF and CDC, have given out specific guidance.

ACF is asking we “Provide a strong justification for your payment request to include details such as the program name, time period covered by the payment request, a clear description or summary of approved expenses or activities and, as applicable, the approved budget line categories for expenditures (e.g., Personnel, Fringe, Supplies, Travel, Contractual, Other).”

CDC is asking “we provide Notice of Funding Opportunity Number, Grant Number, Budget Period, Reason for Payment Request Justification: Payment Justification: Payroll and Fringe for Staff, Payment Justification: Subcontractor Payments, Payment Justification: Supplies, Payment Justification: Other – publications, insurance, professional services, and Summary total of the requested cost by budget category.”

All other agencies, including one NIH agency, are starting to slowly require similar details to ACF based on Defend the Spend emails we received from those agencies after requesting payment.

OGC is working to provide as many of the details and justifications we can. We are working with our University of Information System (UIS) and cross campus partners to create process solutions in order to pull in newly required data with the payment request process. We are not yet sure of the full impact on our department partners and how/when we will need to seek additional justification from you for these payment requests.

During this transition we will reach out if we need to request justification details from you and we appreciate timely responses to any requests.

We will continue to monitor and share additional changes and improvements to our process.  

Final Payment for Award Terminations - If an award has been fully terminated, payment requests for those awards will be paused until a final amount is determined for that last payment request. These terminated requests require a specific process, and we will directly work with departments navigating a termination for these final requests.

CONTRACTS SERVICES

NIH No Cost Extension Approval Documentation for Outgoing Subs

To comply with the new guidance, please make sure you either submit your approval from the prime sponsor for any NCE using the attachment field in our amendment formstack request form or be prepared to provide that if we reach out.

Our team will gather this documentation before drafting any outgoing NCE until further notice.

Statements of Work & Budget Tips for Outgoing Research Services Agreements and Practice Participation Agreements

SOWs: if you are utilizing either of these contracting mechanisms through our team, then that means there is no subrecipient involved and we need to avoid using subrecipient/subaward terms of art.

For example, instead of calling the external entity a “Site” or their personnel “Principal Investigator” use “Location” or “Practice” or “Hospital” or “Service Provider” or “Project Leader” or “Point of Contact.” Instead of calling it a “Study” or “Research Project” call it a “Project” or “Activity” or “Work” or “Services."

Budgets: For any funds outgoing from a Fund 34 or Fund 35 speedtype, no indirect costs should be allowed. Fund 35 speedtypes should also only be utilized to directly benefit our internal faculty’s research and not to benefit any other entity. Please ensure the individual costs of the budget also support the research.

For example, we can pay a Post Doc student to assist with analysis of our research data and agree to fly them to help us present at a conference, but we cannot pay for the Post Doc to fly around the country for student activities at the request of their institution.

PRE AWARD

NIH Proposals

When an Other Significant Contributor (OSC) is involved and that individual is affiliated with a foreign institution or is in a foreign country this meets the definition of a foreign component, the applicant must check “Yes” to the foreign component question.

In the Application:

• Check “Yes” to the question: “Does this project involve activities outside of the United States or partnerships with international collaborators?”
• In Field 6.a (Identify countries): List the country or countries involved.
• In Field 6.b (Optional Explanation): You may enter a brief note such as:  “OSC: Dr. Jane Doe (Country)”

Required Attachment:

• Include a “Foreign Justification” document in Field 12 (Other Attachments).
• Start with the heading “Foreign Justification”.
• Explain why the foreign OSC is necessary for the project (e.g., unique expertise, access to specific data or populations, specialized equipment).
• Name the file: Foreign Justification.

FISCAL COMPLIANCE & TRAINING

OGC TEAM TALKS

Save the Date! The next Team Talks session will be on June 11, 2025 at 10:30 AM. The topic is Sponsored Research Policy Restructure. To register, please click here.

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