NIH RPPR Tips for Administrators

Introduction

NIH requires that a Research Performance Progress Report (RPPR) be submitted periodically based on the terms of the award. The RPPR is completed in eRA Commons by the Principal Investigator (PI), often with assistance from their Research Administrator, but must be submitted by a MSU Signing Official in Contract and Grant Administration (CGA). Progress reports require careful attention and should contain enough information to help NIH assess the project’s status. Providing a thorough report to NIH should facilitate the timely review of the report and the release of the next increment of funding.

CGA often receives questions related to NIH RPPR submissions from both MSU and NIH. The following guidance is intended to address the most frequent inquiries and assist MSU PIs and Research Administrators in completing an RPPR with information that meets NIH’s expectations and requirements.  Questions regarding the RPPR should be sent to cashmanagement@cga.msu.edu.

High-Level Tips

• NIH Instructions: See the NIH and Other PHS Agency Research Performance Progress Report (RPPR) Instructional Guide for official guidelines: https://grants.nih.gov/grants/rppr/index.htm
• When to begin report: Start the progress report as EARLY as possible.
• Interim RPPR: If the PI has submitted a renewal application on or before the date a Final Research Performance Progress Report would be required for the current competitive segment, then submission of an Interim RPPR in eRA Commons is required.
• Routing the report: All RPPRs need to be routed in the system for review and submission to the Signing Official. The route option is currently located under the three dots next to the Award Number in the RPPR Menu.
• Post-submission questions: PIs and their Research Administrators must be prepared to respond to questions about the progress report from the NIH Grants Management Specialist (GMS). The GMS may provide a short turnaround time for responses, which must be routed through/confirmed by MSU’s Signing or Administrative Official on the RPPR.

Section-Specific Tips

Section A – Cover Page:

Section B – Accomplishments:

This section is used by the agency to assess whether satisfactory progress has been made during the reporting period. NIH closely reviews Accomplishments, therefore providing sufficient information for NIH’s evaluation is important.

B.3 - Competitive Revisions or Administrative Supplements

• Include information pertaining to your Revision or Administrative Supplement if you have a component.

B.4 - What opportunities for training and professional development has the project provided?

• MSU Individual Development Plan Standard Language for NIH RPPR:

  "Michigan State University does not have a centralized official policy regarding the use of IDPs. We allow individual departments/colleges the flexibility to create IDPs that best fits their needs while providing resources and guidance to assist in the process. MSU central administration strongly encourages colleges to develop and use IDPs for graduate students and postdoctoral researchers in ways that best achieve the desired outcomes."

Section C – Publications:

• The PI is responsible for maintaining proper records and verifying compliance of all publications.
• PIs cannot enter information about publications directly into the RPPR record. They must keep publications up to date and compliant with the Public Access policy via My NCBI. If publications are not compliant, the PI will receive warnings upon RPPR submission and be required to ensure compliance prior to award issuance.
• Step-by-step: See Appendix

C.5.C – Data Management and Sharing

The RPPR will Automatically Indicate if this section is 'Applicable' or 'Not Applicable' to the 2023 NIH Data Management and Sharing Policy based on data in the system.

If Applicable:

To add Data Management and Sharing Plan (DMSP) information, click the 'Add DMSP Information' button. To edit a current entry, click the 3 dots next to the Data Type. For each Data Type identified in the approved DMS Plan, provide the requested data.

• If data has not been generated and/or shared as outlined in the approved Plan, describe why, and identify any corrective actions that have or will be taken to comply with the approved plan.

If changes are required to the DMSP:

• In the description, enter the effective date of requested change, the rationale and justification for the requested change(s) and describe how the revised DMS Plan impacts the budget for the coming and future budget period(s).
• Upload the DMS Plan as a PDF file, it MUST be named “DMS Plan Revision” (without the quotations).

Section D – Participants:

D.1 - Individuals who have worked on the project

• List the names and effort of all personnel that have worked at least one person-month on the project during the reporting period, regardless of the source of compensation.
• The PD/PI’s effort must be listed even if it was less than 1.0 calendar month.
• Use the appropriate person months (calendar, academic, and/or summer months), to 1 decimal place (e.g., 1.2 months).
• As a reminder, all PD/PIs on NIH awards are required to have measurable effort.
• A Commons ID is required for all individuals with a postdoctoral, graduate or undergraduate role (NOT-OD-13-097). The Commons ID is also required for individuals supported by a Reentry or Diversity Supplement. Departments should contact CGA (cashmanagement@cga.msu.edu) to request/create a Commons ID or to associate MSU to an existing Commons ID.

D.2.C - Changes in Other Support

• Typically applicable. Use updated Other Support documents to complete this section.
• Provide acting and pending support for all new senior/key personnel.
• Provide updated other support for all senior/key personnel for whom there has been a change in active other support.
• If a previously active award has terminated and/or if a previously pending award is now active, update by annotating accordingly.
  • https://grants.nih.gov/sites/default/files/other-support-format-page-rev-10-2021.docx
• Verify that individuals are not over committed. If they are, provide an overlap justification summary with specifics on how the over commitment will be resolved.

Section E – Impact:

E.4 - What is being spent in foreign countries

• Include subawards only. If there are no subawards to foreign organizations, please enter, “No money has been spent in foreign country, involvement strictly collaborative” (See: Frequently Asked Questions (FAQs) | grants.nih.gov )

Section F – Changes:

F.2 - Actual or anticipated challenges or delays and actions or plans to resolve them

• Describe only significant challenges that may impede the research (e.g., accrual of patients, hiring of personnel, need for resources or research tools, COVID, Disaster Event) and emphasize their resolution. If you plan to indicate in G.10 that there is an unobligated balance of 25% or more, then use F.2 to describe factors that may have contributed to the unobligated balance.

Section G – Special Reporting Requirements:

G.4 - Human Subjects

• Needs to be completed in ASSIST and moved to “Ready for Submission” to allow final submission.
• New Human Subject information requires updating the status of the prior ASSIST record to ‘Work in Progress’. Work in Progress allows the enrollment report to be added.
  1. Update the submission status on the left to work in progress (if not already work in progress)
  2. Click on the HSTC Post Submission tab
  3. Click on view next to the study you wish to update
  4. In the study go down to 2.9 – enrollment report, click view
  5. Click edit
  6. Update the report with the correct numbers
  7. Click save and release lock, go back, save and release lock.
  8. Click return to summary on the left side.
  9. Once returned to summary, on the left click update submission status.
  10. In the pop up click the submit without adding note link.
  11. Contact CGA to submit the report once the status has been updated

G.8 - Project/Performance Sites

• The Primary Performance Site should be Michigan State University

G.9 - Foreign Component

• Provide Organization, Name, Country and Description of each foreign component.
• The following grant-related activities are significant and must be reported:
  • involvement of human subjects or research with live vertebrate animals;
  • extensive foreign travel by grantee project staff to collect data, or conduct surveys or sampling activities; or
  • any grantee activity that may have an impact on U.S. foreign policy.
• Examples of other grant-related activities that may be significant are:
  • collaborations with investigators at a foreign site anticipated to result in co-authorship;
  • use of facilities or instrumentation at a foreign site; or
  • receipt of financial support or resources from a foreign entity

G.10 - Estimated Unobligated Balance

• The “total approved budget” includes the amount awarded for the current year and any authorized carryover from the previous budget period that required prior approval. If the unobligated balance is greater than 25% of this amount, an explanation and a plan for expenditure of those funds in the next budget period is needed.
  • If you are anticipating that the remaining balance on an award may be close to 25% with carryover considered, it is suggested that Question G.10.a be answered yes.
• The justification should explain why funds would remain at the end of the year.
  • Any unanticipated delays with suppliers, delays with hiring, or other issues should be addressed.
  • The justification should state the balance as of the end of RPPR budget year. The NIH is aware that this is an estimate and can change.
• Please check your Notice of Award to see if carryover requires agency approval through the Grants Management Specialist (GMS).
  • If agency approval is required, Question G.10.c is not a formal request for carryover into the following year.
    • If carryover is anticipated, a general description of what may be planned for the carryover can be listed. After the grant year is complete, the final unobligated balance is calculated during the expenditure review process and a formal request should be sent to the GMS.
    •  As the unobligated figure is finalized and the financial report is submitted, please work with CGA to draft the carryover request. CGA will submit as an Authorized Official.
  • If agency approval is not required, provide a general description of how it is anticipated that the funds will be spent, according to the award timeline.

G.11 - Program Income

Although most MSU NIH awards do not include program income resulting in an answer of no, this section must be complete.  If the award does have program income, select yes.

G.12 - F&A Costs

Complete if change in subaward location will change F&A costs.

Appendix:

What to Do When You Receive an NIH Non-Compliance Notice

Submitting an NIH award progress report (or Research Performance Progress Report (RPPR)) that cites publications failing to comply with the agency’s public access requirement can cost PI’s time and money. Minutes following the submission a non-compliance notice is issued to the PI’s email inbox. The notice, which is shared with the award’s NIH program officer (PO) as well as the University’s signing official (SO), freezes the RPPR process.

To fix the notice and allow the stalled RPPR to be processed, PI’s need to bring each of these publications into compliance and provide proof to the NIH. Failure to do so could lead to the award being cancelled.

This is a serious situation, but one that PI’s can successfully navigate by following a few simple steps:

1. Determine each non-compliant article’s submission status:
   • To determine an article’s submission status, PIs should check the citation on their NCBI My Bibliography and see if it has been submitted to the NIHMS. Articles without an NIHMSID number in the Public Access Compliance field of the citation may not have been submitted.
   • Check the NIHMS system (https://www.nihms.nih.gov) to see where the paper is in the submission process. Warning: the NIHMS system does not always allow individuals who are not a party to the submission to see the article’s status.
2. Contact the authors. Contact the journal. Submit, if necessary:
   • If an article has not been submitted, PI’s may want to reach out to the article’s authors to see if they would be willing to submit the article to the NIHMS. PI’s can also reach out to journals to see if they have a policy of submitting accepted manuscripts to the NIHMS. If the authors or journals will not submit, the responsibility falls on the PI(s) associated with the paper through an award. They will need to submit a copy of the accepted version of the paper along with all figures, tables, and supplementary information through the NIHMS.
3. Wait for the PMCID:
   • Once an article has been submitted to the NIHMS and received two approvals from a designated reviewer—an associated author or PI—it is uploaded into PubMed Central and receives a PMCID. The NIHMS submission process takes roughly 4-6 weeks. Articles already cited in the PI’s My Bibliography and linked with an award will automatically change to compliant when a PMCID is issued.
4. Generate a PDF Report (aka, Proof):
   • Once all articles linked to a specific award are compliant on the PI’s My Bibliography a PDF report can be generated.
   • Here’s how to create a PDF Report:
     1. Log into your My NCBI My Bibliography
     2. Click on Filter citations and select an award > Click on the Awards Filter > You should only see those citations linked to the award selected
     3. Click the radial at the top of the list selecting all articles
     4. Click on Manage citations then the Compliance Report (PDF) link
     5. A pop-up box will ask you to enter the PI’s name and starting page number, if necessary. Click on the Download PDF button to generate the report.
     6. Review the report to ensure that all previously non-compliant citations have a Complete status.
5. Submit the PDF report to NIH:
   • To provide evidence of compliance to NIH, the PI will need to either:
     1. Reply to the non-compliance notice email with the PDF Report, OR
     2. ask their SO to provide a copy through a PRAM (Progress Report Additional Materials) link available through the PI’s eRA Commons account.
   • Notices typically indicate the NIH’s delivery preference.
   • In some instances, the award’s program officer (PO) or Grants Management Specialist may request that PDF reports be sent directly to them.
6. Time’s up!
   • NIH may request that PI’s provide proof of compliance before an article has made it through the NIHMS. In these cases, it is highly recommended that the PI contact the award PO directly to explain the situation as soon as possible. If the article has already been submitted, the PO may waive the PDF report requirement or delay its deadline.