The Department of Health and Human Services has issued a new Health and Human Services Grant Policy Statement (HHS GPS). The policy went into effect October 1, 2006 and affects new awards and renewals AFTER that date. It supersedes in its entirety the Public Health Service Grants Policy Statement (PHS GPS) that was dated April 1, 1994.
It is important to note that the National Institutes of Health Grants Policy Statement (NIH GPS) dated December 1, 2003 will continue to apply to NIH grants and cooperative agreements. Thus, the grants affected include those issued by HRSA, CDC, SAMHSA, FDA, AHRQ, among others, but not NIH.
There is one major rule change that needs to be highlighted. Retroactive cost transfers must be corrected within 90 days of OCCURRENCE, not within 90 days of DISCOVERY.
Here is the new rule compared with the NIH wording:
HHS GPS: "Permissible cost transfers should be made promptly after the error occurs but no later than 90 days following occurrence unless a longer period is approved in advance by the GMO.”
NIH GPS: “Cost transfers to NIH grants by grantees, consortium participants, or contractors under grants that represent corrections of clerical or bookkeeping errors should be accomplished within 90 days of when the error was discovered.”
Under this new policy, cost transfers that are initiated more than 90 days after the occurrence of the error would be considered unallowable. Timely review of statements and prompt error correction is critical to stay within this threshold.
Go to the new HHS GPS for more information.
If you have questions, please contact your Grant Accounting DHHS contact.
As posted in Grant Accounting list serv on 2/7/07