Federal Grant Compliance Checklist: The Practical Basics

Federal grant compliance is not one requirement — it is a system of interlocking obligations that sit on top of each other across the life of an award. CASRAI has published in-depth guides on the individual pieces of that system: the Uniform Guidance itself, effort reporting, internal controls, indirect cost rates, subaward negotiation, and more. What’s missing between those pieces is an answer to a simpler question: on any given day, what does “staying compliant” actually require, and in what order? This page is that connective overview — a practical, lifecycle-ordered checklist that names each requirement once and links out to the deep dive, rather than restating it.

If you’re looking for the full regulatory text or a step-by-step walkthrough of any single item below, follow its link. If you’re trying to see the whole system at a glance — or brief a new hire on what “compliance” covers before they specialize — start here.

Grant administration vs. grant management: is there a real difference?

Searches for these two phrases often return the same content, and inside a US research institution the terms are frequently used interchangeably — but where a distinction is drawn, it tracks a real difference in scope, not just word choice.

• Grant administration is the operational, compliance-driven execution of an already-awarded grant according to its terms: proposal routing and submission, budget and account setup, ongoing financial and effort compliance, reporting, and closeout. This is what CASRAI’s own research administrator role guide describes, and it maps directly onto the field’s standard pre-award/post-award functional split.
• Grant management, especially in the broader nonprofit- and foundation-grants software industry (where the phrase is most heavily used in marketing and vendor content), tends to describe a wider, strategic, end-to-end lifecycle — including funding-opportunity strategy, outcomes measurement, and program evaluation — that extends beyond the operational/compliance scope “administration” usually covers in a university research office.

In practice, most US research-administration literature (NCURA, RACC/CRA, SRAI) uses “research administration” or “grant administration” for the university-side operational work covered by this checklist, and doesn’t draw a sharp technical line between “administration” and “management” the way some grants-management-software vendors do. Treat the two search phrases as pointing at the same underlying set of institutional obligations unless a specific source states otherwise.

The framework underneath all of it

2 CFR Part 200 (the OMB Uniform Guidance) is the single federal framework almost everything below traces back to: cost allowability (Subpart E), pre-award requirements (Subpart C), post-award requirements including internal controls and subrecipient monitoring (Subpart D), and audit requirements (Subpart F). Individual funding agencies layer their own policy on top of that common baseline — NIH through its Grants Policy Statement, NSF through the PAPPG — but the Uniform Guidance is the floor every federal grant sits on, regardless of agency. Every item below either comes directly from the Uniform Guidance or from agency policy built on top of it.

The practical checklist

1. Pre-award: before you accept federal money

• Confirm the funding instrument type — a grant, cooperative agreement, and contract carry different obligations. See Grant vs. Contract vs. Cooperative Agreement.
• Build the budget and budget justification to the sponsor’s format (e.g., NIH’s modular budget threshold) and write the narrative correctly — see Budget Justification Narrative.
• Apply the correct indirect cost (F&A) rate and base. Understand F&A rate, MTDC, and when the de minimis rate applies instead of a negotiated rate. If the award is from NIH, check current status on the 15% indirect cost cap litigation before assuming a flat rate applies.
• Screen every proposed party — including any planned subrecipients — against SAM.gov exclusions before submission. See debarment and suspension verification.
• Collect conflict-of-interest disclosures from PI and key personnel. See Conflict of Interest Disclosure Form and conflict of interest disclosure.
• Route the proposal through the correct office — many institutions split pre-award work from post-award, or organize it departmentally vs. centrally; see Departmental vs. Central Sponsored Programs Office.

2. Award setup and ongoing operational compliance

• Establish internal controls aligned to the GAO Green Book or COSO framework, as required by 2 CFR 200.303 — see Institutional Internal Controls for Federal Grant Compliance.
• If the award involves subawards: correctly classify each party as a subrecipient or contractor, issue the right subaward agreement, and negotiate its terms. See Subaward Agreement Negotiation and the FDP subaward templates.
• Monitor subrecipients for the life of the subaward, not just at issuance — see subrecipient monitoring.
• Track any mandatory or voluntary cost-share commitments made in the proposal. See cost share (mandatory) and cost share (voluntary).
• Screen international collaborations and materials transfers for export control exposure. See Export Control and International Research Collaboration and export-controlled research.
• If the institution receives $50 million or more in federal awards subject to Subpart E in a fiscal year, maintain Cost Accounting Standards documentation — see Cost Accounting Standards Disclosure Statement (DS-2).
• Ensure responsible conduct of research training is complete and tracked where the sponsor requires it. See Responsible Conduct of Research (RCR) Training.

3. Financial and effort compliance, during the award

• Certify effort using a method that matches salary actually charged to the award. See Effort Reporting Methodologies.
• Before charging any cost, apply the Uniform Guidance’s allowability tests — necessary, reasonable, allocable, consistently treated, GAAP-compliant, not double-counted toward cost-share (2 CFR 200.403–200.405), covered in full in the Uniform Guidance guide.
• Recover indirect costs correctly against the applicable base. See indirect cost recovery and indirect costs (overheads).
• Track spend-down against the period of performance. See burn rate (grant).
• Route no-cost extensions and other prior-approval actions through the correct process rather than assuming automatic approval. See no-cost extension (NCE).
• File financial and progress reports on the schedule set in the sponsored research agreement and the post-award phase — subrecipient reporting deadlines are typically set earlier than the prime’s own sponsor deadline, to allow time to compile the combined report.

4. Closeout and audit readiness

• Complete closeout phase steps — final financial and technical reports, property/equipment disposition, invention and patent reporting where applicable.
• Retain federal award records — financial records, supporting documentation, and statistical records — for three years from the date the final financial report is submitted (longer if litigation, a claim, or an audit is open, or the institution is notified in writing of an extension), per 2 CFR 200.334.
• Know whether the institution is subject to a Single Audit this fiscal year, and prepare for it rather than reacting to it.
• Understand the three severity tiers an auditor can assign a finding — control deficiency, significant deficiency, material weakness — and how each is likely to affect the institution’s risk profile going forward. Covered in the internal controls guide.
• Respond to any grant audit finding with a documented corrective action plan, not just a one-time fix.

Frequently asked questions

What is a federal grant compliance checklist, really?

It’s not a single form or a one-time signoff — it’s a set of obligations that apply at different points across the award lifecycle, most of them originating in 2 CFR Part 200 or in agency-specific policy built on top of it. A generic checklist (like this one) is useful for orientation and for making sure nothing is missed at a given phase; the specific compliance work itself (an effort report, a subaward negotiation, a Single Audit) is where the actual detail lives.

What’s the difference between grant administration and grant management?

See the section above — in US research-institution usage the terms largely overlap, with “administration” the more common term for the operational/compliance work this checklist covers. “Grant management” is used more broadly, and more often outside the research-university context, to include funding strategy and outcomes evaluation as well.

Who is actually responsible for grant compliance monitoring at a research institution?

It’s distributed, not owned by one office. The central or departmental sponsored programs office typically owns institution-wide compliance monitoring and reporting; the PI and lab/department own day-to-day cost allowability and effort accuracy; internal audit or a compliance office typically owns periodic testing and Single Audit coordination. See the departmental vs. central and pre-award vs. post-award guides for how institutions typically split this.

Do federal grant compliance requirements differ by funding agency?

The baseline — cost allowability, internal controls, audit requirements — comes from the Uniform Guidance and applies across federal agencies. Individual agencies then layer their own policy on top: NIH’s Grants Policy Statement and NSF’s PAPPG each add agency-specific rules (budget formats, prior-approval thresholds, reporting cadence) that a research office has to track in addition to, not instead of, the common 2 CFR 200 baseline.

What happens if an institution fails a compliance test during a Single Audit?

The auditor classifies any issue found by severity — control deficiency, significant deficiency, or material weakness — and a material weakness is the one most likely to change how a federal agency assesses the institution’s risk going forward (including a possible high-risk auditee designation). See the Single Audit dictionary term and the internal controls guide for what auditors are actually testing against.

Where to go deeper

Every item above links to CASRAI’s dedicated coverage of that specific requirement. For the wider research-integrity and compliance picture beyond federal grants specifically — human subjects protection, research misconduct, disclosure, data protection — see the Research Integrity & Compliance cluster page.