Grantee Variations Policy

Introduction

A grant variation is a change to a grant. This may include changes to the Funding Period, for example through a delayed start date, a delay during the grant, a change to the end date, and/or changes to the research team, Research Activity or Administering Institution. There are specific circumstances where it is appropriate for an NHMRC grant to be varied. Refer to NHMRC’s Funding Agreement for definition of terms.¹

NHMRC grants are awarded following rigorous peer review of an application, which may include:

• assessment of the Chief Investigator(s)’ research achievements and impact
• quality of the research proposal
• overall feasibility of the application, including Chief Investigator suitability, research environment suitability, budget, and time period.

NHMRC’s Funding Agreement states that “Funds may only be used for the Research Activity for which they were provided” (clause 7.1) and accordingly any proposed grant variations, including changes to the Research Activity or Funding Period, need to be reviewed and approved by NHMRC.

This Grantee Variations Policy applies to all NHMRC funded grants.

Medical Research Future Fund (MRFF) grants administered by NHMRC are managed under the MRFF Grant Variation Policy. Variation requests for MRFF grants will be considered within the scope of the MRFF Grant Variation Policy and Eligible Organisations are to refer to the advice included in the Appendix A to that policy Submitting Medical Research Future Fund (MRFF) Grant Variations for MRFF grants administered by NHMRC available on NHMRC’s website.

Principles

NHMRC may at its sole discretion approve or reject a request to vary a grant. In making its decision, NHMRC will consider each request to vary a grant under this policy relative to the following:

• the individual circumstances outlined in the variation request
• the grant opportunity guidelines under which the grant was applied for
• the fundamentals of the grant that were assessed in the original peer review
• the best outcomes for the grant against its aims and objectives
• whether the grant will continue to align with the purpose of the grant opportunity
• whether the grant will continue to achieve value with relevant Commonwealth money
• any other matters of which NHMRC is aware relevant to the grant, Administering Institution or the researchers involved with the grant.

In addition to the above, NHMRC requires that:

• a variation request be submitted to NHMRC via NHMRC’s grant management system at least one month before the proposed date of effect to allow adequate time for review (requests for variations with retrospective effect will only be approved in exceptional circumstances)
• a grant variation request is not used as a means to meet NHMRC eligibility requirements or to avoid budget adjustments, unless specifically allowed in the grant opportunity guidelines
• by submitting a variation request, the Chief Investigator A and Research Administration Officer (RAO) confirm that all affected Chief Investigators agree to the variation, noting the impact it may have on their suite of grants and hence their eligibility to hold/apply for other grants.

Note for RAOs

All variation requests are to be submitted by the Administering Institution’s RAO. RAOs are the first point of contact for all grant administration matters.

RAOs are to maintain a record of the reason for the proposed variations and any relevant supporting documentation. NHMRC may at any point ask to view such evidence, including evidence that all affected parties have agreed to the change.

NHMRC makes grant payments as per the relevant Schedule and Administering Institutions will be required to manage the flow of funds in accordance with the varied arrangements. Budget adjustments may occur following the approval of a variation (e.g. a variation that shortens the Funding Period).

Note for Chief Investigators

Researchers are not to approach NHMRC for advice on how to manage variations. Where the circumstances for a variation request do not match those listed in this document, Chief Investigators are to consult with their RAOs who may contact NHMRC for clarification. NHMRC will manage exceptional circumstance requests on a case-by-case basis.

It is important for all Chief Investigators to note that variations that extend the end date of the Funding Period may affect their eligibility to apply for grants in future years depending on the suite of grants held.

Exceptional circumstances

For the purposes of this document, exceptional circumstances are considered on a case-by-case basis for each grantee variation type on the premise that to be exceptional the circumstance could not have been foreseen, or was foreseen as a risk but was considered extremely unlikely and is unable to be effectively managed or mitigated within the original project plan.

Submitting a variation

The grantee variation process involves the following steps:

1. The Chief Investigator reviews this policy and the grant opportunity guidelines under which the grant was applied for, then creates and submits the grantee variation request to their Administering Institution RAO using NHMRC’s grants management system.
2. The RAO from the Administering Institution reviews the request in the context of this policy, and the relevant grant guidelines, and if the request is supported by the Administering Institution, submits the grantee variation request in NHMRC’s grants management system. The Administering Institution must maintain a record of, and keep, any relevant supporting documentation.
3. NHMRC reviews the request and makes a decision whether or not to approve (or may seek additional information if required). If necessary, the request will be forwarded to a panel with scientific expertise for a recommendation.
4. The RAO is notified by email of the decision.
5. If the variation is approved, revised schedules are only issued if the grant has transferred to a different Administering Institution.
6. NHMRC’s grants management system is updated where required, for example, Funding Period dates, reporting milestones, and/or budgets may be updated. Payment milestones may also be adjusted for certain variation types.
7. If the variation is rejected, the RAO will be asked to confirm that the grant will continue as originally awarded or as previously approved.

Note that changes to the Funding Period will only be made in calendar month blocks of time.

Types of grantee variations

Types of grantee variations are listed below.  RAOs and grantees should also refer to the grant opportunity guidelines under which the grant was applied for to determine eligibility and variation requirements. All grant variations that are approved by NHMRC are provided without additional funding unless specifically allowed for in the grant offer and/or grant guidelines.

Where a grantee variation request is not covered by the options outlined below, RAOs should email the details of the request to postaward.management@nhmrc.gov.au.

1. Defer commencement date

NHMRC grants are expected to commence on the Schedule commencement date.

Examples of circumstances where NHMRC may approve variations to defer commencement date are:

• when NHMRC receives the variation request prior to the commencement date
• where payments against the grant have not yet commenced
• where institutional approvals needed by the commencement date are not yet in place
• where the Chief Investigator A has a contractual obligation that cannot be met in time to meet the Schedule commencement date
• where key personnel are taking up a temporary position in industry that will support building Australia’s research capacity
• where there are visa issues affecting overseas relocation for Emerging Leadership Investigator Grants
• family-related or personal reasons relating to key specified personnel, including reasons related to the birth and care of children
• where there has been a delay in recruiting key staff needed at the commencement date
• where there has been a delay in establishing arrangements with Participating Institutions.

NHMRC will allow up to 12 calendar months in total from the original commencement date for this variation. Variation requests exceeding 12 calendar months from the original commencement date will only be considered in exceptional circumstances.

The information required for this variation type includes:

• number of months for deferral
• reason for the proposed change.

Grantees should note that deferments of less than 12 months may cause asynchrony with the scheme and potentially affect eligibility for subsequent funding rounds.

2. Defer an in-progress grant

This variation type is expected to be used in the early-to-mid duration of the Research Activity. Use this variation type to request:

• to defer a grant that has passed the commencement date
• additional time due to a delay in relation to the performance of a Research Activity.

Examples of circumstances where NHMRC will approve this variation are as follows:

• family-related or personal reasons relating to key specified personnel, including reasons related to the birth and care of children
• where Chief Investigator A is taking up a temporary position in industry that will support building Australia’s research capacity
• where the research timeline has changed significantly
• where Institutional approvals are not in place as needed during the Funding Period.

NHMRC will allow up to 12 calendar months in total for this variation. Requests to Defer an in progress grant for longer than the allowed 12 calendar months will only be considered in exceptional circumstances.

The information required for this variation type includes:

• number of months deferral
• reason for the proposed change.

Grantees should note that deferments of less than 12 months may cause asynchrony with the scheme and potentially affect eligibility for subsequent funding rounds.

3. Extended Leave requests

Use this variation type for all schemes where this is provided for in the grant opportunity guidelines to request:

• to take extended leave
• to take parental leave.

Please refer to the grant opportunity guidelines under which the grant was applied for specific Extended Leave eligibility.

Note: Investigator Grant CIAs are to submit requests for Extended Leave using the Investigator Grant – Suspend grant – Partial or Full variation type.

Examples of circumstances where NHMRC will approve this variation are as follows:

• family-related or personal reasons, including reasons related to the birth and care of children
• where Chief Investigator A is taking up a temporary position in industry that will support building Australia’s research capacity.

NHMRC will allow up to 12 calendar months in total for this variation. Extended Leave requests that exceed the period allowed either in the Grant Opportunity Guidelines and/or the allowed 12 calendar months total under this policy will only be considered in exceptional circumstances. If approved, all grant payments will be suspended and the end date of the grant will be adjusted to extend the grant by a period equivalent to the period of leave. The information required for this variation type includes:

• number of months deferral
• reason for the proposed change.

Grantees should note that leave requests of less than 12 months may cause asynchrony with the scheme and potentially affect eligibility for subsequent funding rounds.  

4. Extend end date

This variation type is expected to be used close to or in the final year of the Research Activity.

Where the Research Activity has not been completed, the Chief Investigator A may apply to extend the end date of the grant.  Funds that have not been spent by the current end date may be spent during the extension period. There is no separate approval required to spend these funds. Funds can only be spent on the Direct Research Costs of the Research Activity in accordance with the Direct Research Costs Guidelines.

NHMRC will allow up to 12 calendar months in total for this variation. Variation requests that exceed the period allowed either in the Grant Opportunity Guidelines and/or the allowed 12 calendar months under this policy will only be considered in exceptional circumstances.

The information required for this variation type includes:

• number of months extension
• reason for the proposed change.

Grantees should note that extensions of less than 12 months may cause asynchrony with the scheme and potentially affect eligibility for subsequent funding rounds.

5. Change in full-time equivalent 

a) Investigator Grant – Change in FTE

This variation type only applies to Chief Investigators named under the Investigator Grant Scheme. Investigator Grants are awarded on a full-time, part time (Professional) and part time (Personal) basis.

Requests to change the time commitment from the awarded FTE will be considered by NHMRC on a case-by-case basis and must be made with reference to the grant opportunity guidelines under which the grant was applied for.

Reduction of the awarded time commitment may be requested due to:

• A change in the CIA’s professional circumstances
• Career disruption due to a change in personal circumstances
• Exceptional circumstances.

Requests to reduce the FTE may be made for the duration of the grant or for a specified period.

The salary component of the grant will be reduced commensurate with the requested FTE for the period requested.

• In the case of FTE reductions requested for a specified period, the salary component of the grant will revert to the awarded FTE at the end of the requested period.
• The awarded RSP may be reduced commensurate with the reduction in FTE or may be retained at 100% of the awarded FTE. In the case where RSP reductions are requested for a specified period, the RSP will revert to the awarded RSP at the end of the requested period.
• Reductions in FTE will not affect the grant term, which will remain at five years.

Increases to the awarded time commitment may only be requested where the grant was awarded as a part time (Personal) Investigator Grant, and where the personal circumstances of the grantee have changed such as changes in carer responsibility or recovery from an illness or major injury.

• Where a request to increase time commitment is approved, the salary component of the Investigator Grant may be increased pro-rata.
• The RSP component will not be affected and remains at the awarded amount.
• The grant term will remain at five years.

b) People Support and Postgraduate Scholarships – Change in FTE

This variation type applies to Early Career Fellowships, Career Development Fellowships, Practitioner Fellowships, Research Fellowships and Postgraduate Scholarships

Requests to Increase or Reduce the FTE of the grant must be made with reference to the grant opportunity guidelines under which the grant was applied for.

If approved, the salary and/or term of the grant may be increased or reduced commensurate with the FTE and time period requested for the change.
Grantees should note that changes of FTE of less than 12 months may cause asynchrony with the scheme and potentially affect eligibility for subsequent funding rounds.

6. Investigator Grant – Suspend grant – Partial or Full

NHMRC will consider a request to suspend an Investigator Grant (partially or in full) on a case-by-case basis under the following circumstances:

• Career disruption due to a change in personal circumstances
• Temporary professional appointments
• Approved time overseas as an Emerging Leader in accordance with the grant opportunity guidelines
• Relinquishment of salary due to other awards or appointments
• Exceptional circumstances.

Suspensions to an Investigator Grant can be requested as:

• Full suspension – where both the salary and RSP components of the grant are suspended as there is no activity or expenditure on the grant during the period of suspension. If approved, all grant payments will be suspended and the end date of the grant will be adjusted to extend the grant by a period equivalent to the period of suspension.
• Partial suspension – where only the salary component of the grant is suspended and the RSP is retained in full to enable the research activity to continue during the period of absence of the CIA.  If approved, payments for the salary component of the grant will be removed for the period of suspension.

The grant term will remain at five years and the end date will not be affected. 
Grantees should note that full suspensions of less than 12 months may cause asynchrony with the scheme and potentially affect eligibility for subsequent funding rounds.

7. Relinquish grant

Approval of this variation type will result in changes to the reporting requirements, in particular the due date of the Final Report and Final Acquittal Statement.  Examples of circumstances where grants are relinquished include:

• where the Chief Investigator A requests a relinquishment and advises all other Chief Investigators of their request
• where the Administering Institution will no longer support the grant and the grant cannot be transferred.

The required information for this variation type includes:

• proposed date of effect
• reason for the proposed change.

Grants that are relinquished may still count towards a grantee’s eligibility to hold/apply for other grants.

8. Transfer Administering Institution

Examples of when NHMRC may approve a transfer to a new Administering Institution include:

• where the Chief Investigator A requests the transfer and both the relinquishing and new Administering Institutions agree to the transfer
• where the current Administering Institution will no longer support the grant.

An example of when NHMRC may not approve a transfer to a new Administering Institution:

• where the new Administering Institution does not demonstrate a capacity to support the grant for the remaining Funding Period.

The required information for this variation type includes:

• proposed date of effect
• reason for the proposed transfer
• written confirmation obtained from the new Administering Institution that it accepts the administering responsibilities for the grant including the date of effect
• written confirmation the relinquishing Administering Institution agrees to the transfer including the date of effect.

Where NHMRC approves the request to Transfer Administering Institution, the following steps complete the transfer process:

• the relinquishing Administering Institution advises the new Administering Institution of the value of any unspent funds
• the new Administering Institution invoices the relinquishing Administering Institution for the value of the unspent funds
• the relinquishing Administering Institution pays the invoice raised by the new Administering Institution
• NHMRC issues a revised Schedule to the new Administering Institution for acceptance (this may occur before the new Administering Institution’s invoice has been raised or paid); this Schedule will not include unspent funds from the relinquishing Administering Institution
• If the effective date is not the first day of the month, payments to the new Administering Institution will commence as of the start of the next month
• payments to the new Administering Institution will not commence until the new Schedule is accepted in NHMRC’s grants management system
• the relinquishing Administering Institution submits the Transfer Acquittal statement to NHMRC disclosing the unspent funds that have been/will be paid to the new Administering Institution.

9. Change to research plan

This variation type to change the research plan is where there is a change in the aims or objectives as specified in the application for the Research Activity and as assessed in the peer review process for funding.  Improvements to the research techniques used to achieve the research plan (e.g. new, cheaper or more accurate technique or technology becomes available) do not require a variation request.

NHMRC will only approve a change to the original or previously approved Research Activity in exceptional circumstances, or where the change results from an institutional ethics committee approval process.

Applications for approval to change partners included in peer reviewed applications will be considered on a case-by-case basis.

The required information for this variation type includes:

• details of exceptional circumstances (if applicable)
• change required by institutional ethics committee (if applicable)
• details of how the proposed change will affect the completion of the grant in accordance with its peer reviewed objectives and outcomes in balance with the best outcomes for the grant
• proposed date of effect.

10. Change to Chief Investigators

While Chief Investigators are expected to remain on the grant for the full duration of the grant/Funding Period, a request for approval to remove, change or add Chief Investigators will be considered by NHMRC in limited circumstances.

NHMRC will not normally approve the addition of a new Chief Investigator unless it is for the reason of replacing a departing Chief Investigator and their replacement is assessed as being necessary.

NHMRC will not normally approve the removal of a Chief Investigator.  At the time of application Chief Investigators agree to participate as a Chief Investigator on the grant team for the duration of the grant.

Requests to change Chief Investigators on grants with a single Chief Investigator (for example, Investigator Grant) will only be considered in certain circumstances.

Examples of circumstances where NHMRC may approve a change to Chief Investigators on a grant include:

• where NHMRC is provided with evidence that a change in the Chief Investigator’s employment:
  • prevents them continuing in the peer reviewed Chief Investigator’s role (for example the change of employment results in the researcher no longer being able to receive Commonwealth grant funding)
  • means the Chief Investigator A is no longer going to be based in Australia for 80% of the grant duration and a change to their position on the grant team is necessary
  • means a Chief Investigator A has been determined by the employer to be permanently disabled/incapacitated and unable to continue in the role.
• where a Chief Investigator dies requiring a change in Chief Investigator roles on a team based grant.

Where the Chief Investigator A on a single Chief Investigator grant dies or has been deemed permanently disabled/incapacitated and the Administering Institution proposes for the grant to continue, the RAO is to contact postaward.management@nhmrc.gov.au and discuss requirements to submit a proposal for NHMRC consideration of whether it is appropriate and feasible for the grant to continue. 

Long service leave, sabbatical or leave without pay will not be considered as changes in employment that would require a change to Chief Investigator.
Changes to Chief Investigators for NHMRC grants may result in a budget adjustment.

The required information for this variation type includes:

• details / evidence which demonstrates how a change in employment prevents the Chief Investigator from continuing in their peer reviewed role
• details of how the grant will still be completed in accordance with its peer reviewed objectives and outcomes in balance with the best outcomes for the grant
• proposed date of effect.

In addition, the Administering Institution must retain the following:

• confirmation from all affected Chief Investigators that they agree to the proposed change
• confirmation from new Chief Investigators that their addition to the team will not result in eligibility issues, and their Profile/CV section in NHMRC’s grants management system is up to date.

Note that an inability for an Administering and Participating Institution to reach formal agreement should not be a reason to request a Change to CI as all contributing parties should have already agreed to the application and formal agreement is a requirement under the Funding Agreement.

Where a budget agreed in the application to support the work of a Chief Investigator has not translated into a budget allocation to the Participating Institution after award, if agreement cannot be reached, the grant may need to be terminated² rather than a ‘Change in Chief Investigator’ variation request. 
If NHMRC approval is given for a Chief Investigator to be removed from a grant team, the grant may still count towards that Chief Investigator’s eligibility to hold/apply for other grants.

Note: Administering Institutions are no longer required to advise NHMRC of a change to Associate Investigators. Administering Institutions may approve a change to Associate Investigator membership on a grant, provided the change is not detrimental to the project and the Research Activity as described in the signed Schedule for the grant will still be undertaken.

11. Change in supervisor

This variation type only applies to the Post Graduate Scholarships scheme. Administering Institutions may approve a change in supervisor provided the change is not detrimental to the project and the change and the reason for change are recorded in NHMRC’s grants management system, and the Research Activity as described in the signed Schedule for the grant will still be undertaken.

For Post Graduate Scholarships, where a change of supervisor has taken place, a letter from the supervisor is required to be provided to NHMRC.

Enquiries

Any enquiries about this policy should be directed to postaward.management@nhmrc.gov.au

Footnote

¹ Or the relevant Grant Agreement under which the grant was entered into.

² NHMRC may take any of the actions specified in clause 15.2 of the NHMRC Funding Agreement, including terminating a grant, if it reasonably considers that the Administering Institution or a Participating Institution has failed to comply with a term or condition of the Funding Agreement, the requirements of being an Administering Institution, NHMRC Approved Standards and Guidelines or a Funding Policy.