"Please Sir, I want some more…" – Expanded Authority, You Get Just One
Oliver Twist, a Charles Dickens classic. So of course I will now put my own twist on it.
For some time now, long before I came to NIH, NIH provided a clause in almost all Standard Terms of Award that waives the requirement for prior approval for specified actions, in this case, the No Cost Extension (NCE). This has been referred to as part of the 'expanded authorities.'
Now, think of poor Oliver… at each meal, he gets just one small bowl of oatmeal to eat. This is kind of like the No Cost Extension. With each award that allows for it, the grantee is permitted one NCE — to extend without funds the final budget period of a grant's project period by up to 12 months. Typically, this is done within 90 days of the project end-date, when in the Action column of the Status search results screen the Extension link appears. This is your one bowl of oatmeal, the one chance to extend the award period under the Expanded Authority. If you want more, you will have to ask. So in the classic scene of film, theater, and literature, Oliver bravely goes up to Mr. Bumble and asks for more. Likewise, to extend an award a second time without seeking additional funding, you must get prior approval (See Prior Approval Requirementssection of the NIH Grants Policy Statement).
Currently there is a lot of work going on to meet the requirements outlined in the Uniform Guidance concerning the NCE. And in the interim, we have noticed an increasing trend of people asking for "more" in the middle of the project period. For example, let's say Oliver has a 4-year project, but toward the end of year 2, he realizes he will need more time for that part of the project. So he asks for and is granted a No Cost Extension at that point, extending the project under expanded authority.
Now comes the new project end date, and again, Oliver needs just a little more time. However, Oliver will not get the Extension link in Commons. His option to exercise the expanded authority has already been used when he requested the first extension at the end of year 2.
And while it is true that the request can be up to 12 months, the number of requests under expanded authority is still one. If Oliver originally asks for a 6 month extension, he will not be able to come back later and submit another extension for the other 6 months. His bowl is empty of NCEs under expanded authority.
In either scenario, Oliver needs to take the empty bowl in hand, and seek prior approval from the Grants Management staff of the awarding institute or center to extend the project a second time. (See pertinent section of the NIH Grants Policy Statement).
The point here is to be sure that you understand that expanded authority permits you to extend a project just one time without justification, regardless of when or for what number of months you exercise that option. After that, you must get prior approval from the awarding Institute.
"Some conjurers say that number three is the magic number, and some say number seven. It's neither my friend, neither. It's number one." – Fagin
When You're Not Yourself – The Dangers of Sharing Credentials
I love Snickers. And I think a lot of people love Snickers. At Halloween, we buy the mixed bag of the mini candy bars, and Snickers are always the first to go. Then I am stuck with MilkyWays, or worse, 3 Musketeers. And that makes me snarky. Like Betty White playing football, I'm just not myself!
Something far worse than sneaking off with all the Snickers, is when someone, who is not you, signs into eRA Commons as you. Intentionally.
It is a practice that we hear about far too frequently; a Principal Investigator (PI) or Signing Official (SO) giving their credentials to someone else. It is a dangerous practice. eRA Commons works in a specific manner to ensure the scientific, reporting, and financial processes it manages are protected and legally binding. Understandably, sometimes it is just easier and/or more convenient to have someone else click a button. But the processes are there for your protection as well as ours.
We go to great pains to ensure your information is secure and private. Just check out the full Privacy Notice to get an idea of that effort. But if organizations circumvent the process by giving out user names and passwords to unauthorized people for the sake of convenience, then not only are they putting the organization at risk, but the entire process as well.
For PIs, they need to remember they are responsible for the integrity of the science and the accuracy of much of the reporting. Simply allowing someone else to complete those tasks without review and oversight puts them, their reputation, and the reputation of their institution at risk.
If you, or people at your institution, have adopted this practice, let me remind you that eRA Commons has many tasks that can be delegated to an individual with the assistant role (ASST). Here are just a couple of examples; a PI can delegate his Progress Report authority to any active user within his same institution; or any active Commons user can grant another active user the ability to enter his Personal Profile by delegating PPF authority.
Assistants can complete much of the required work, while leaving the act of routing or submitting in control of the PI or SO. For a complete list of direct delegations, you can visit the eRA Commons Online Help.
For SOs, they need to remember they are the legal agent of the institution. They also have access to all the awards the institution has been granted. Should proprietary information about research projects and/or personal information be released, intentionally or not, by someone using the credentials of the SO, it will be the SO that is held accountable.
As is often heard around here, "We cannot systematically prevent a person's bad behavior." You have to do that. Just like me, eating the candy that I am supposed to passing out to the kids in costumes.
Video Debut! – 4 New Tutorials to Help You Out
The first video is How to Register an Institution in eRA Commons. This video is 6 minutes and 40 seconds long and reviews the steps to get your institution registered in eRA Commons.
The second video, How Signing Officials Create Accounts in eRA Commons, goes over the details of creating scientific and administrative account by Signing Officials and Account Administrators.
How Trainees Get Accounts in eRA Commons is the third video. Trainees are invited to eRA Commons by their Principal Investigators (PI). This tutorial reviews the steps a PI takes to initiate that invitation.
The fourth and final video is How Scholars Register in eRA Commons. Scholars are the one exception to the rule and can register themselves with eRA Commons.Scholars are individuals who have received an advanced degree and are mentored under the guidance of NIH researchers for a temporary and defined period of time.