As we explained in “Don’t Let Dollars Expire Upon Payment Management System Drawdown,” NIH grant recipients have 120 days from the end of a performance period to liquidate obligations by drawing funds from the Payment Management System (PMS). After 120 days, PMS will automatically reject requests to withdraw funds.
To give a practical scenario: Suppose your lab received a shipment of reagents 1 month before the end of an award’s performance period and your supplier sends a quarterly bill to collect payment, which in this case arrives 2 months after the end of the performance period. You’ll have about 2 months’ time to pay that cost using money from the award’s designated PMS subaccount; if you take longer (i.e., beyond 120 days of your project period ending) then PMS will not allow you direct access to the money.
What happens if you are beyond the 120-day liquidation period with bills still to pay?
First, check the status of your PMS subaccount, which can be open, pending closed, or closed. Subaccounts reach closed status in PMS at the end of the Closeout process. Once a subaccount is closed there is no workaround to access the funds—your institution will need to pay any remaining obligations using other money. Leeway exists only for public health emergencies or natural disasters.
Otherwise, for awards beyond the 120-day liquidation period and with rare circumstances, you may submit a prior approval request to the grants management specialist assigned to your award, receive approval, and then submit a payment request in PMS. In your prior approval request, list the PMS subaccount (e.g., award document number), NIH grant number, amount of funds being requested, and a justification for the late payment request.
We also require that you describe actions your institution will put in place to prevent similar situations in the future. Keep in mind, we will show less leniency toward organizations that repeatedly request payments beyond the 120-day liquidation period.
After approving a request, we will notify PMS to allow the corresponding withdrawal of funds.
For more information, refer to the February 23, 2023 Guide notice and Section 8.6—Closeout of the NIH Grants Policy Statement.
If you have questions about the policy, email OPERAFFRInquiries@od.nih.gov. For concerns about a particular award, instead contact the assigned grants management specialist.