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Part 5, Chapter 19: Manual Exhibit 5-19-2A

Program Official Responsibilities in the
Administration of PHS Grants

147.0 Background and Purpose
147.1 Applicability
147.2 Appointment, Organizational Placement and Responsibilities of Program Officials
147.3 Functions of Program Officials
147.4 Letter to Grantee
147.5 Qualifications for Program Officials

147.0  Background and Purpose

  1. The proper development, funding, and management of grant programs requires the active participation of staff who are trained and experienced in a variety of disciplines and who maintain complementary interaction with a wide range of scientific and business organizations.  These personnel include the program staff concerned with scientific, technical, and programmatic topics and grants management staff concerned with business management aspects of grant programs.  Close coordination between and understanding of the responsibilities of these team members is vital to the achievement of program objectives.  It is particularly important that the role of the Program Official as the PHS scientific/technical official for a particular grant or cooperative agreement be well defined and understood.  Program Officials may also be known by their functional or programmatic titles, e.g., Health Science Administrators, Public Health Advisors, or Project Officers.
  2. Program Officials and Grants Management Specialists each have necessary and complementary roles in assuring proper stewardship of Federal grant funds.  Each is responsible for basic staff work which must be integrated in the decisions and actions impacting on the selection and continued funding of projects, yet they must work as a team.  The proper stewardship of Federal grant funds depends on the integrated efforts of (1) the Program Official in determining the appropriateness and value of proposals as well as establishing the provision of expertise in the technical or scientific areas of the administration of grant projects and (2) the Grants Management Specialist in observing the policy and the use of good business practice in the administration of grant programs for which they are responsible.
  3. Throughout the entire grants process, from application review to closeout, the heads of the awarding offices must be assured of the appropriateness of decisions made concerning applications and awards from both the programmatic and administrative management perspectives.  These officials must rely on the advice, guidance, and recommendation of both the program and grants management staff.  The Program Official is a key staff resource for information on applications/projects.  Many decisions and determinations, including some of the most important in the administration of grant programs, can be made only by persons with appropriate programmatic expertise.  Therefore, input from Program Officials is required in a number of areas which include, for example, determinations of the adequacy of an applicant?s plans to accomplish project objectives, the extent of a grantee?s compliance with programmatic requirements, and the quality and degree of a grantee?s programmatic performance.
  4. The purpose of this part is to delineate the role of the Program Official in order to ensure an appropriate degree of consistency in carrying out those responsibilities which relate to the administration of grants throughout PHS and to address the qualifications for such individuals.  This part complements PHS Grants Administration Manual Part 101, which establishes and delineates the role of the Grants Management Officer in the administration of PHS grants.

147.1 Applicability

This part is applicable to all PHS grant and cooperative agreement programs, including discretionary, formula, and block grant programs.  When the term *grant? is used, it also includes cooperative agreements.

147.2 Appointment, Organizational Placement and Responsibilities of Program Officials

  1. Program Officials are involved in numerous preaward and post-award activities covering a wide range of responsibilities.  It is important to delineate clearly assigned responsibilities as well as a point of contact on programmatic issues for applicants and recipients of awards.
    1. With respect to each grant program, the official who has authority to award grants shall:
      1. Clearly specify the organizational unit/personnel responsible for performing (or seeing that someone else performs) the functions in 147.3 below.
      2. Ensure that either the unit has staff with the expertise necessary to perform the functions or that satisfactory central service or cross servicing arrangements are in place.
    2. With respect to each grant award, the official who has authority to award grants shall appoint a specific Program Official as the person responsible for the technical/programmatic/scientific aspects of each grant to perform the functions in 147.3(d), (e) and (f) below.
    3. The emphasis placed on the functions in 147.3 may vary from program to program depending on the relative technical expertise of PHS staff, the nature of the program, the nature of the recipient organization, the nature of the assistance relationship, the fact that some functions may be centralized, thereby limiting the Program Official?s role in a particular aspect of the grant process, and other factors.
  2. With reference to a particular project, the Program Official ordinarily relates to the principal investigator/project director of the grantee or applicant institution.  In this capacity, the Program Official is the focal point for the technical/programmatic/scientific aspects of the application review, negotiation, award, and administration of grants.  Although the role of the Program Official is an important one, it is not an independent one.  As a key member of the team, the Program Official shares with others, principally review staff and the Grants Management Specialist, the responsibility for the effectiveness of grant projects which fulfill the agency?s overall objectives and priorities.
  3. To assure proper balance between business management and programmatic considerations, Program Officials must be placed in an environment that is independent of those offices that are responsible for the business management functions.  Program Officials must be free to exercise their professional judgment with respect to their areas of responsibility without undue pressures or controls.  With such freedom, however, Program Officials have the responsibility to exercise judgment and prudent stewardship over Federal funds in accordance with the highest standards of professional and ethical conduct.  As a minimum, Program Officials shall perform their duties in accordance with the standards listed in the following paragraphs of this section.
  4. Program Officials shall give due consideration to the significance and impact of their actions upon established program goals and objectives.  They shall coordinate with other responsible staff on programmatic and technical matters and with the grants management staff on all business matters which impact on the activities of the grant-supported project and/or application.
  5. Program Officials shall carry out all functions for which they are responsible with due professional care, fairly and objectively, and in a timely and consistent manner.  Special care must be taken to ensure that the Federal Employee Standards of Conduct are followed and no person or organization is provided information that is not available to the public.

147.3  Functions of Program Officials

  1. Program Official functions may be categorized either as general programmatic duties or specific responsibilities in conjunction with the administration of a grant.  Paragraph (b) below discusses the general programmatic duties; paragraphs (c) through (f) discuss the specific grant administration responsibilities.  As stated above, these functions may vary from awarding component to awarding component.
  2. General Programmatic Duties.  The Program Official has a major role in the development of program regulations, guidelines, and application instructions.
    1. Under the direction of the head of the awarding office, establishes or participates in the establishment of goals for new programs or activities and plans of action for implementation.  This may include the development of new grant programs in response to legislation or changes in grant program emphasis and priority.  The development of new or changes in existing grant programs are implemented through the issuance of regulations and program announcements.
    2. In order to obtain competition for financial assistance to the maximum extent practicable, assists in the development and wide dissemination of program announcements and other information to stimulate interest and ensure a fair opportunity for response among qualified applicants.
    3. In connection with cooperative agreements, the Program Official assists in identifying the substantial Federal involvement.  This information must be included in the program announcements, when published.
  3. Stimulation of Applications
    1. Where appropriate for highly focused activities, initiates meetings with organizations and/or potential principal investigators to explore the potential for development of grant applications.  When such meetings are held, Program Officials must be careful that they do not confer a competitive advantage by providing information to any one entity which is not available to all potential applicants or to the public.
    2. Upon request, provides technical assistance, as appropriate, in the development of applications.  This technical assistance may include:
      1. Providing advice on the development of the project plan, including goals, objective setting, task delineation, staffing patterns, scope of services, program management systems, etc., as necessary.  The applicant must be cautioned, however, that the ultimate responsibility for preparing a meritorious application is the responsibility of the applicant.  The final application must be found meritorious by objective/peer reviewers whose viewpoint may differ from that of the Program Official.
      2. In close coordination with the Grants Management Specialist, providing general information on business management policies and referring to the grants management staff, for appropriate action, requests for information on budget formulation, financial systems, personnel systems, property management, completion of business items on the application, etc., that may have been addressed to the Program Official, together with any necessary recommendations based on the scientific or technical programmatic aspects involved.
      3. Providing guidance to applicants on possible linkages with other resources.
      4. For programs which require a preapplication, providing preapplication reviews in order to determine the appropriateness of the proposal to the solicitation topics, the inclusion of required activities, if any, and project plan compliance with program regulation and guidelines.
      5. Providing explanations of programmatic requirements, regulations, guidelines, technical evaluation, and funding criteria.
  4. Application Review/Preaward Activities.  The Program Official serves as a primary program resource to the objective/peer review committee, e.g., study section, and performs the activities listed below.  However, the functions may differ in those PHS agencies which use a centralized organizational component for review.
    1. As necessary, responds to questions raised by the review committee regarding program policy, goals and objectives, specific areas of need, and other relevant program issues.
    2. Provides comments or raises concerns which should be brought to the attention of the decision-making official and the persons responsible for negotiating the final award.
    3. As appropriate, explains to the applicant any programmatic deficiencies in the grant application identified by the review committee.  Provides technical assistance to unsuccessful applicants in order to assist them in revising their applications for resubmission.
    4. Assists in assuring that the budget, financial plan, and all business administration aspects of the application reflect project needs and program requirements.
    5. Assists the Grants Management Specialist in the negotiation with the prospective recipient of the grant budget, particularly in technical matters.
    6. As appropriate, works with the applicant to ensure that any programmatic concerns/comments (e.g., human/animal subjects) identified in the review process are resolved prior to award and recommends special conditions, if necessary, for inclusion in the award document.
  5. Post Award.  Because of the need to present a uniform and consistent position to grantees, most post-award activities involve a particularly close coordination between program and grants management staff.  Although activities listed below are presented in terms of Program Official responsibilities, there needs to be a team approach with appropriate collaboration and exchange of information between Program Officials and Grants Management Specialists.  The Program Official:
    1. Provides direct consultation and assistance to grantees concerning programmatic or technical matters as requested.
    2. Conducts site assessments as warranted by program or project needs or as requested by the grantee to substantiate progress and compliance with laws, regulations, and policies.
    3. Evaluates all projects for programmatic performance, progress, and any changes (e.g., in methodology), utilizing information gathered from on-site reviews, review of financial, progress and other reports, correspondence, and other sources.  Identifies potential or existing programmatic or business management problems and shares with appropriate staff information and/or findings concerning those problems.  Participates with other staff, as appropriate, in the resolution of those problems and recommends actions for the resolution of the problem(s).
    4. Serves as focal point for responding to technical and programmatic correspondence from the grantee.
    5. Provides input to grants management staff on correspondence from grantees on business management issues.
    6. Provides information as to whether or not special programmatic conditions placed on the award have been met and should be released or other action taken.
    7. Assists in assuring that grant project expenditures are in accordance with law, regulations, and grants policy.
    8. Thoroughly documents all on-site reviews and discussions with the recipient which may influence the administration of the project in the awarding office?s official grant file, which is maintained by the Grants Management Office.
    9. Communicates regularly with any other program staff having responsibility for various aspects of the program to keep apprised of the progress of individual projects and of issues which need resolution.
    10. Assists the recipient, where appropriate, with respect to the development of an action plan for the conduct of subsequent years of the grant project, including the review of the technical aspects of any requests for extension of the final budget period.
    11. Provides input to grants management staff on requests for any rebudgeting or other actions which require PHS prior approval.
  6. Closeout.  The Program Official shall provide assistance to grants management and other Federal personnel in the closeout of the project including, but not necessarily limited to, a review and/or evaluation of the final progress report, publications, invention statements, and other required reports.

147.4  Letter to Grantee

A letter or other notice should be provided to each grantee at the time of the award, designating both a technical/programmatic contact (Program Official) and a business representative (Grants Management Specialist) as contact persons for the grantee.  The letter should provide information on the responsibilities of each.  For example, the Program Official?s functions would normally include responsibility for monitoring, providing technical and programmatic assistance, and reviewing the project relative to all scientific, technical, and programmatic aspects while the business representative will normally be responsible for business administration of the project and resolving nonprogrammatic questions.

147.5  Qualifications for Program Officials

The selection of individuals by awarding offices to serve as Program Officials is a very important aspect of grants administration.  Given the diversity and complexity of PHS grant programs, it is vitally important that people selected to serve in this role have the qualifications, character, and ethics to exercise good stewardship over the Federal resources involved in a manner which avoids an actual or apparent conflict of interest.  It is the responsibility of awarding offices to select individuals who are experienced and who have, or will soon acquire, the training, education, and technical knowledge necessary to perform these functions and responsibilities.  The following factors shall be given special consideration:

  1. Formal education or special training (including Government conducted or sponsored courses) in both the programmatic area for which the individual will serve and in the functions and responsibilities of Program Officials.
  2. Knowledge of applicable laws, regulations, and policies.
  3. Knowledge of the awarding office goals and priorities for the program and the funding mechanisms available so that technical assistance provided will be focused.