Direct comparison
NIH vs. DOE Grant Requirements
How NIH (eRA Commons, 2 CFR 200) and DOE (PAMS, 2 CFR 910, national labs) differ in grant systems, rules, and research security.
Side-by-side comparison
| Dimension | NIH | DOE |
|---|---|---|
| Primary mission focus | Biomedical and public health research, funded through 27 institutes and centers, each with its own study sections and program priorities. | Physical sciences, energy, and national-security-adjacent research, funded primarily through the DOE Office of Science program offices (and, separately, NNSA for nuclear-security work). |
| Electronic post-award system | eRA Commons — the portal for status tracking, Just-in-Time submissions, progress reports (RPPR), no-cost extensions, and closeout. | PAMS (Portfolio Analysis and Management System) — the Office of Science's system for managing proposals, peer review, and, for many recipients, post-award reporting. |
| Application submission path | Prepared and submitted through ASSIST or Grants.gov, then tracked through the rest of the lifecycle in eRA Commons. | Universities and small businesses submit through Grants.gov; DOE national laboratories and other federal agencies may submit proposals directly in PAMS instead. |
| Governing cost/administrative regulation | 2 CFR Part 200 (Uniform Guidance) as implemented through the NIH Grants Policy Statement. HHS previously ran its own supplemental codification at 45 CFR Part 75; that was retired effective October 1, 2025, in favor of citing 2 CFR 200 directly. | 2 CFR Part 910 — DOE's own agency codification of the Uniform Guidance — governs administrative requirements, cost principles, and audit requirements, and also sets DOE-specific rules on rights to data and inventions for awards made to for-profit recipients. |
| National laboratory / technology-transfer layer | No equivalent network. NIH's technology-transfer footprint runs through standard Bayh-Dole Act invention reporting (iEdison), the same mechanism used across most federal research agencies. | DOE funds and administers a network of Government-Owned, Contractor-Operated national laboratories. A grant recipient collaborating with a national lab may need a separate Cooperative Research and Development Agreement (CRADA) or user agreement layered on top of standard grant terms, and 2 CFR 910's data/invention-rights provisions are more elaborated than NIH's default Bayh-Dole handling. |
| Research-security posture | Subject to the same government-wide research-security baseline as other federal science agencies: foreign-affiliation and current-and-pending-support disclosure requirements and prohibitions on participation in a malign foreign talent recruitment program. | Subject to that same baseline, with additional layers tied to the national-security-adjacent work performed at some DOE sites and DOE's own generative-AI use policy for staff and contractors (see DOE AI Policy). |
| Award closeout | Closed out through eRA Commons under NIH's own closeout procedures (see NIH Closeout). | Closed out through PAMS under the general federal closeout timeline set by 2 CFR 200.344, without an NIH-style dedicated closeout module. |
| Cognizant federal agency for indirect costs | For most NIH-funded institutions, HHS's Division of Cost Allocation is the cognizant agency (see Cognizant Federal Agency) that negotiates the institution's facilities-and-administrative rate. | A DOE-funded institution's cognizant agency depends on which federal agency provides the preponderance of its federal funding — that is frequently HHS or a Department of Defense component (e.g. the Office of Naval Research) rather than DOE itself, unless DOE genuinely is the largest funder. |
Common questions
FAQ
Do NIH and DOE grants follow the same cost principles?+
Both ultimately trace back to 2 CFR Part 200 (the Uniform Guidance), so the core concepts — allowable, allocable, and reasonable costs; direct versus facilities-and-administrative costs; single-audit thresholds — are the same. DOE implements the Uniform Guidance through its own agency codification at 2 CFR Part 910, while NIH implements it through the NIH Grants Policy Statement under HHS's implementation. The differences show up in agency-specific supplemental terms, not in the underlying cost-principle framework.
What is PAMS in DOE grant management?+
PAMS (Portfolio Analysis and Management System) is the DOE Office of Science's web-based system for managing proposals submitted in response to funding announcements and the peer reviews of those proposals. Universities and small businesses generally submit through Grants.gov, while DOE national laboratories and other federal agencies may submit proposals directly in PAMS; many recipients also use PAMS for post-award reporting.
Does a DOE grant always involve a national laboratory?+
No. Most DOE Office of Science grants go directly to universities and other non-federal entities with no national-laboratory involvement at all. A national laboratory becomes relevant specifically when a recipient collaborates with one — for example, using lab facilities or co-investigating with lab staff — at which point a separate instrument like a Cooperative Research and Development Agreement (CRADA) or user agreement may sit alongside the grant.
Which agency is the cognizant federal agency for a university that receives both NIH and DOE funding?+
Cognizance for indirect-cost-rate negotiation is assigned per institution based on which federal agency provides the preponderance of that institution's federal research funding, not per award. A research university with substantial NIH funding will typically have HHS's Division of Cost Allocation as its cognizant agency even for its DOE-funded projects, unless DOE genuinely represents the largest share of its federal support.
