NIH eFFR (SF425) Implementation Update
As you may know, the Office of Management and Budget has implemented a requirement to consolidate the Financial Status Report (FSR or SF-269/SF-269A) and the Federal Cash Transaction Report (FCTR or SF-272/SF-272A) into a single form known as the Federal Financial Report (FFR or SF-425/SF-425A). In addition to consolidating the reporting forms, the reporting periods and due dates are to be standardized. While federal agencies have implemented the use of the FFR to report cash transaction data via the Payment Management System (PMS) since January 2010, some of the agencies are still in the process of transitioning to the full use of the FFR for financial expenditure reporting (previously done using the SF269) via eRA Commons.
Beginning, January 1, 2011, NIH will make the use of the new Electronic Federal Financial Report (eFFR) mandatory for financial expenditure reporting. The reporting data will be done through a new “eFFR” feature that is scheduled to be released in the eRA Commons on July 23, 2010. The FFR expenditure data will be identical to the current FSR data however grantees will be reporting cumulative data only for the reporting period. NIH will implement the use of the FFR by retaining the reporting period of the FFR that coincides with the budget period end date. While the due dates for final FFR’s submitted through eFFR will not change, the due dates for annual FFR’s will be due 90 days following the end of the calendar quarter of the budget period end date. Following are the due dates for annual and final reports and schedule for the annual FFR report due dates:
- Annual FFR’s: The due date for annual FFR’s will be 90 days after the end of the calendar quarter in which the budget period ends. For the purposes of the pilot, Penn will be submitting FFRs for awards with budget period end dates between January 31 and June 30, 2010. FFR’s for budget end dates between January 31 and March 31 would normally be due June 29, 2010; however the FFR due date will be delayed until August 29, 2010 to allow for submission through eFFR pilot system in July. FFRS for budget period end dates between April 30 and June 30 will be due September 29, 2010. (see schedule)
- Final FFR’s: The due dates for final FFR’s will continue to be 90 days following the end of the budget period end date.
Prior to implementing the use of the eFFR for expenditure reporting via eRA Commons, NIH will be testing the use of the feature in a Pilot Module between July 24, 2010 and September 30, 2010. Penn was asked to participate in the Pilot in May 2010 and in consideration of the timing of the mandatory requirement, the volume of FSR’s submitted during that quarter and our financial reporting goals; Penn has agreed to participate. In order to accommodate the testing requirements, NIH has asked pilot participants to delay the submission of FSR’s (269’s) that would normally be due in the month of May and June 2010 via eRA Commons until the new feature is released. The Office of Policy for Extramural Research Administration (OPERA) has provided formal permission, in writing, for pilot grantees to submit the FSR’s that were due in May and June 2010 when eFFR is made available for the pilot. This is expected to occur on or about July 24, 2010 and the FFR will be used to report expenditure data.
In order to accommodate the pilot phase requirements and to ensure that we can meet the reporting deadlines during the period of the implementation, Penn issued the FSR’s that were due in May 2010 via the commons. The reports that are due this month, June 2010, will be issued via eFFR in July 2010 when the feature is made available. There will be no change in our existing closeout practices for the final FFR’s. The final reports will be prepared and submitted beginning the first day the feature is available. The Annual FFR’s will be submitted according to the new FFR reporting due dates. ORS is investigating how we can modify the BEN COA attributes to reflect the new reporting due dates for annual FFR’s and will provide updates as information is available. Please visit the following links for additional information regarding the implementation of the FFR (SF425). If you have any questions regarding reporting dates and the NIH eFFR pilot, please contact your ORS accountant.