NIH will phase in the Standard Form (SF) 424 Research and Related (R&R) dataset over the next two years in accordance with the federal initiative to simplify and standardize application data and forms across the government. At the same time, NIH will encourage full use of electronic submission through Grants.gov, the central posting and receiving site for 26 grant-making agencies.

NIH is committed to the success of the federal initiative and plans to replace the Public Health Service (PHS) 398, currently used by applicants for NIH grants, with the SF424 R&R. This conversion effort involves numerous funding mechanisms and tens of thousands of applications ranging widely in size and complexity. 

Transition to the new form and electronic submission will be by funding mechanism as per NIH Notice NOT-OD-05-067, issued on August 19. Applicants for NIH Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) grants (R41, R42, R43 and R44) will be the first required to use the 424 R&R, effective for the December 1, 2005, submission date. See full article in this issue. Conference grants (R13 & U13) will be next, effective for the December 15, 2005, submission date; AREA grants (R15) will follow, effective for the January 25, 2006, submission date.

New Application Process

In accordance with the new application process, grantee institutions must have a Data Universal Numbering System (DUNS) number, be in the Central Contractor Registry (CCR), register with Grants.gov, and establish an institutional profile and person profiles in the eRA Commons. NIH is advising applicant organizations to register early since each registration can take several weeks to be processed.

After registration is completed, the applicant can download, complete and submit the 424 R&R using PureEdge™ software, which is provided by Grants.gov. Alternatively, research institutions can establish an electronic system or engage a Service Provider to transmit applications as XML data streams to Grants.gov.

Differences between the SF424 R&R and the PHS 398

Most data fields on the 424 R&R are the same or similar to those NIH currently collects on the 398; however, there are some significant differences. Earlier this year, the Grants Management Working Group identified data field and data format discrepancies.

For NIH-required data that the 424 R&R does not collect, there will be several 398-specific supplementary forms. These include a cover letter, cover page supplement, research plan, modular budget and checklist.

The eRA 424 Transition Team and the Joint Program/Review Working Group are meeting to address other differences between the forms and their impact on NIH grant administration business practices. Some differences are:

• The 424 R&R collects some data elements not captured on the 398.

Example: 424 R&R Cover #16b (Total Federal and Non-federal Funds)

Resolution: NIH programs generally do not involve cost sharing or matching. There will be an agency-specific instruction to leave 16b blank unless otherwise directed in the program announcement.

• Some 424 R&R and 398 field lengths or formats differ.

Example: 424 R&R Cover #11 (Title) is 150 bytes; eRA stores titles up to 81 bytes.

Resolution: For now, there will be an agency-specific instruction warning the applicant that a title with more than 81 characters will be truncated.

• Some response options (picklists) on the 424 R&R and 398 differ.

Example: On the 424 R&R, there are three choices for Type of Application: Preapplication, Application, and Changed/Corrected Application. The 398 does not include the Preapplication option.

Resolution: Include an NIH-specific instruction that "Preapplication" does not apply unless noted in the program announcement.

• Some 424 R&R instructions may be confusing to NIH applicants.

Example: The 424 R&R Cover #6 (EIN) instructs applicants to enter the 9-digit TIN or EIN assigned by the Internal Revenue Service. Many NIH grantees have an extended EIN (12 digits) assigned by the Department of Health and Human Services (DHHS).

Resolution: Include an agency-specific instruction requesting the applicant to enter the DHHS EIN, if assigned.

• The 424 R&R and the 398 sometimes use different units of measurement.

Example:  For the budget, the 424 R&R collects Person Months and the 398 collects Percent Effort.

Resolution: Still under consideration. One alternative is for NIH to calculate Person Months from the 424 R&R Budget Section A. NIH may need to change its business practices.

424 R&R Training and Outreach for NIH Staff

In preparation for receiving the first group of 424 R&R applications this fall, NIH staff needs to become familiar with the new 424 R&R form set and the 398-specific supplements. On August 4, there was a 424 R&R preview session at the Natcher Main Auditorium. Go to http://videocast.nih.gov/PastEvents.asp (DHHS only) to view the videocast of the 45-minute presentation and 75-minute question-and-answer panel session.

Background materials, including a PDF sample of the 424 R&R application package, are available to NIH extramural staff at http://odoerdb2.od.nih.gov/oer/training/esa/esa_training_20050804.htm. For more information, go to http://www.grants.gov/CustomerSupport, grantsinfo@nih.gov and the eRA Commons Support Page at http://era.nih.gov/commons/index.cfm.