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FIC Funding Strategy
Reporting
and Record Retention Guidance for NIH Grantees
Posted July 2002
Foreign grantees must submit annual
Financial Status Reports (FSRs) on Standard Form SF-269, in
U.S. dollars, whether or not they are under the Streamlined
Noncompeting Award Process (SNAP). This
is due to the fact that foreign grantees are not paid through
the Payment Management System (PMS) and, therefore, do not submit the SF-272 (which
the National Institutes of Health (NIH) uses
in lieu of the annual FSR for domestic awards under SNAP).
The currency rate in existence at the time the FSR is prepared
should be used in preparing the report. Record retention requirements
are the same as those for domestic grantees.
Grantees generally must retain financial
and programmatic records, supporting documents, statistical
records, and all other records that are required by the terms
of a grant, or may reasonably be considered pertinent to a
grant, for a period of 3 years from the date the annual FSR
is submitted. For awards under SNAP (other than those
to foreign organizations and Federal institutions), the 3-year
retention period will be calculated from the date the FSR
for the entire competitive segment is submitted. Those grantees
must retain the records pertinent to the entire competitive
segment for 3 years from the date the FSR is submitted to
NIH. Foreign organizations and Federal institutions are
required to submit annual FSRs for all awards, including those
under SNAP, and must retain these records for a period of
3 years from the date of submission of the annual FSR to NIH.
See 45 CFR 74.53 and 92.42 for exceptions and qualifications
to the 3-year retention requirement. Those sections also specify
the retention period for other types of grant-related records,
including F&A; cost proposals and property records. See 45
CFR 74.48 and 92.36 for record retention and access requirements
for contracts under grants.
If you need to get the form for filling
out a FSR on Standard Form SF-269, it is available at: http://grants.nih.gov/grants/fsr_sf269_long.pdf. If you have a funded FIC grant or cooperative agreement
and have questions about filling out the SF-269 form, you
can contact Valerie Thomas, Office of Financial Management (OFM), NIH at 301-402-9123.
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