The MRAM PRAM Report

1. The MRAM PRAM Report Carol Rhodes, Associate Director, OSP January 16, 2014

2. NIH Public Access Policy • “…all investigators funded by the NIH submit or have submitted for them to the National Library of Medicine's PubMed Central an electronic version of their final, peer-reviewed manuscripts upon acceptance for publication, to be made publicly available no later than 12 months after the official date of publication…”

3. Progress Report Additional Materials PRAM • Functionality in eRA Commons available for RPPRs. • Request for PRAM comes in from NIH to PI via e-mail, cc. SO (OSP). • PRAM allows PI to enter current publication information and route to SO in eRA Commons. • PI/dept notifies OSP Grant and Contract Coordinator (GCC). • OSP sets up a “Pre-Award Notification” (PAN) in SPAERC. • OSP submits information to NIH and attaches submitted PRAM information to PAN for internal UW record.

4. Recent Activity • Currently, PRAM notifications are only used by NIH to request additional information regarding compliance with the public access policy • ↑ in PRAMS received over the last three months • ↑ in restricted awards due to non-compliant publications over the last three months Confusing Mix: • PRAM request sent and responded to, then no restriction (as expected) • No PRAM request sent, then restricted award arrives (not expected)

5. Restricted Awards Specific restriction language used each time: “In the absence of compliance with NIH Public Access Policy (NIH Grants Policy Statement, Section 8.2.2), as detailed below, this award is issued with the following restriction: all funds for this grant are restricted with the exception of those costs associated with patient care and/or animal care (as appropriate). These funds remain restricted until the outstanding publications have been submitted to Pub Med Central and the NIH awarding institute has issued a revised NOA removing this restriction. Failure to comply with this term may result in further actions that may affect future funding.”

6. Process for Funding Action(FA) • If the project does not have patient care or animal care costs: Please place BN in Status 3 and allocate all funds to 37-99.  Upon receipt of revised NGA, OSP will send PAC lifting the restriction. • If the project does have patient care or animal care costs: Please allocate {dollar amount for patient care/animal care costs} and put the remainder of the funds into 37-99. Upon receipt of revised NGA, OSP will send PAC lifting the restriction.

7. What are practical implications of restriction? “Status 3” does not allow expenditures to post to the budget number. 37-99 denotes a “restricted funds” category in the financial system and is encumbered (to assist in monitoring). Once restriction lifted per PAC, all expenditures incurred for the budget period may post. Please be mindful of the NIH Public Access Policy. Any expenditures incurred on an Advance Budget Number and later disallowed are the responsibility of the department (see GIM 9).

8. Resources • NIH Notice regarding use of PRAMs for RPPRs: http://grants.nih.gov/grants/guide/notice-files/NOT-OD-13-035.html • UW overview of how to use PubMed Central: MRAM report June 2013 • NIH Public Access web page: http://publicaccess.nih.gov • Award Compliance Report “how-to” for reporting publications in eRA Commons: http://www.nlm.nih.gov/pubs/techbull/nd12/nd12_myncbi_pdf.html