Award Financial Management & Compliance
This sub-cluster covers the financial administration of an award once it has been made: budget execution, allowable-cost determinations, effort reporting, cost transfers, subaward monitoring, financial reporting, and closeout. It is the counterpart to proposal development on the other side of the award decision — where that sub-cluster ends at submission, this one begins the moment a notice of award is issued and continues through the final financial report. For US federal awards, the governing framework is the Uniform Guidance, codified at 2 CFR Part 200, "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards." Uniform Guidance consolidated what were previously separate OMB circulars covering cost principles, audit requirements, and administrative rules into a single regulation, and it sets the baseline definitions used throughout this sub-cluster: allowable, allocable, and reasonable costs; direct versus facilities-and-administrative (indirect) costs; and the single-audit requirements that apply to institutions spending federal funds above a statutory threshold. This material corresponds to the "Financial Management" and "Legal Requirements" domains of the Certified Research Administrator (CRA) Body of Knowledge, reflecting the field's own division between the technical accounting side of award management and the regulatory and legal obligations layered on top of it — conflict-of-interest disclosure, export control, data rights, and audit findings among them. Pages here are written for the research administrator or department financial manager who needs to determine whether a specific cost is allowable, how to document an effort certification, or what a subrecipient monitoring plan must include, rather than for the proposal-writing stage that precedes an award.
Guides
Pass-Through Entities, Subrecipients, and the Subaward Statement of Work
What makes an organization a pass-through entity, the obligations 2 CFR 200.332 attaches to that status (including all 14 required subaward data elements), and how the statement of work has to hold a subaward together.
Truth in Negotiations: When Certified Cost or Pricing Data Is Required
The current TINA / certified-cost-or-pricing-data threshold, the FAR 15.403-1 exceptions that exempt a contract even above it, and the DoD-specific $10 million statutory threshold that took effect July 1, 2026 but hasn’t yet caught up in the FAR text.
Incurred Cost Submissions and the DCAA Audit
A practical guide to the FAR 52.216-7 incurred cost submission: who must file, the six-month deadline, the DCAA ICE model and adequacy checklist, the audit process, and how this differs from a 2 CFR 200 indirect cost rate proposal.
Limitation of Cost and Limitation of Funds Notices
How and when to send a 75% Limitation of Cost (FAR 52.232-20) or Limitation of Funds (FAR 52.232-22) notice, what it must contain, and a template letter.
NSF Salary Rules: The Two-Month Limit
NSF has no fixed-dollar salary cap like NIH. Instead, its PAPPG policy limits senior/key personnel salary requests to two months of their own regular salary per year, across all NSF awards combined.
Cost Transfers: Justifying a Late Charge Without an Audit Finding
How to justify a late cost transfer so it survives audit review: what the 90-day convention actually is, what an adequate justification contains, and the fact patterns that turn a transfer into a finding.
Participant Support Costs: What Qualifies and Why It Matters
Participant support costs are a federally defined, walled-off budget category for stipends, travel, and fees paid to non-employee participants in NSF-funded meetings and training activities — excluded from MTDC and restricted from rebudgeting without prior approval.
Section 889 Compliance: Prohibited Telecom on Federal Awards
A practical compliance guide to Section 889 of the FY2019 NDAA: which covered telecommunications vendors are prohibited, how the representation requirement differs between FAR contracts and 2 CFR 200.216 grants, and how the obligation flows down to subawards and subcontracts.
NSF Project Reports and the Public Outcomes Report
NSF grants carry three separately-deadlined reports filed in Research.gov: the annual project report (due 90 days before the budget period ends), the final annual project report, and the public Project Outcomes Report (both due 120 days after the award ends).
NIH Inclusion Enrollment Report: Completing the Form
A step-by-step walkthrough of the NIH Inclusion Enrollment Report (IER): where it lives inside RPPR Section G.4, the planned vs. cumulative tables, the OMB race/ethnicity/sex categories, and when individual-level CSV upload is required instead of manual entry.
Federal Grant Budget Mechanics: Prior Approval, Rebudgeting, and Cost Allowability
A practitioner’s guide to federal grant budget mechanics: which changes need agency prior approval, how NIH and NSF differ, the 25% effort-reduction rule, carryover of unobligated balances, exactly what NSF participant support costs cover and what cannot be rebudgeted out of that line, and what makes a cost allowable under 2 CFR 200.
Effort Reporting and Payroll Certification for Federally Funded Research
How to calculate person-months, reconcile committed effort against actual effort, and apply the NIH salary cap under the current 2 CFR 200.430 internal-control standard — with worked calculations, a person-months table, and what auditors look for.
Executive Order 14332 and What It Changes for Federal Research Awards
What Executive Order 14332 actually directs, which agencies it binds, and how it is driving OMB’s proposed 2 CFR 200 rewrite and NSF’s PAPPG deferral — verified against the primary Federal Register text, with a timeline and practical implications for research administrators.
FAPIIS, Suspension and Debarment, and Federal Award Integrity Checks
What FAPIIS records and discloses, how suspension and debarment work, when Build America Buy America and Section 889 actually reach a research institution, and a requirement-to-applicability map for sponsored-programs offices.
Cost Accounting Standards (CAS) for Universities: DS-2 and Consistency Requirements
Which Cost Accounting Standards actually apply to universities (only four of the full 19), what the DS-2 disclosure statement covers, and how the consistency principle catches direct-vs-F&A cost-charging conflicts before an auditor does.
The Single Audit (2 CFR 200 Subpart F): Requirements and Thresholds
The $1,000,000 expenditure threshold, how major programs are determined, what belongs on the SEFA, the Compliance Supplement’s role, questioned-cost reporting, and the Federal Audit Clearinghouse submission deadline under 2 CFR 200 Subpart F.
NICRA: Negotiated Indirect Cost Rate Agreements Explained
What a NICRA is, who issues it, the four rate types, how the MTDC base is built and what it excludes, and a full worked calculation applying a negotiated rate to a budget.
Fly America Act: Rules, Exceptions, and Open Skies Agreements
What the Fly America Act requires, how the U.S. flag carrier and code-share flight-number tests work, the four qualifying Open Skies agreements (and the DoD carve-out), the recognized necessity exceptions, and what happens when travel is booked non-compliantly.
Simplified Acquisition Threshold and Micro-Purchase Threshold (2026)
The current federal Simplified Acquisition Threshold ($350,000) and micro-purchase threshold ($15,000), the documentation and competition rules that attach at each tier, and how they apply to federal award recipients under 2 CFR 200.
NIH Salary Cap 2026: Current Figure, History, and How to Calculate It
The FY2026 NIH salary cap is $225,700 for awards issued Oct-Dec 2025, then $228,000 from Jan 1, 2026. Since FY2025 the cap also covers indirect salaries. Full history since 2017 and a worked calculation.
Federal Procurement for Research Institutions: The Full Decision Sequence
The single map for federal-award procurement: which threshold applies, what competition and documentation it requires, which purchasing vehicle to use, how to classify supplies vs. equipment, when prior approval is needed, and what happens to title and disposition afterward — with links to the full page on every step.
Equipment Justification Letter: Requirements, Format, and a Worked Example
An equipment justification letter documents why a capital equipment purchase is needed and allowable on a federal award, required under 2 CFR 200.439 for general purpose equipment or special purpose equipment at $10,000 or more. This guide covers required elements, how it differs from a capital equipment request form or capital budget request template, review, and a worked example.
Accounting for Fabricated Equipment on Federal Grants
How research institutions account for equipment built in-house from purchased parts and labor: setting up a fabrication/WIP account, when it capitalizes as equipment, and why materials and labor get different indirect-cost treatment under 2 CFR 200.
Equipment Titling Under Federal Awards: Conditional Title vs. Federally-Owned Property
Federal award equipment can carry conditional title, federally owned title, or exempt (unconditional) title — three distinct regimes under 2 CFR 200.312 and 200.313 with different rules for use, disposal, and disposition.
Equipment and Capital Expenditures Prior Approval Under 2 CFR 200.439
A practical guide to 2 CFR 200.439: when equipment and capital expenditures need federal prior approval, the $10,000 special-purpose-equipment threshold, general purpose equipment rules, and why end-of-project equipment purchases draw audit scrutiny under allocability principles.
Subrecipient Equipment Purchases: Who Holds Title When a Subrecipient Buys Equipment Under a Subaward
Under 2 CFR 200.313(a), title to equipment a subrecipient buys with subaward funds vests in the subrecipient itself, not the prime recipient — subject to federal-interest use, recordkeeping, and disposition conditions the prime must still monitor.
Procurement Card (P-Card) Compliance for Research Purchases on Federal Awards
A practical guide to keeping procurement card (P-card) programs compliant on federally funded research: micro-purchase thresholds, unallowable costs, split-purchase risk, and the internal controls auditors look for.
Lease vs. Purchase Analysis for Federally Funded Equipment (2 CFR 200.465 Rental Costs)
A practical, compliance-grounded guide to leasing vs. buying equipment on a federal award: what 2 CFR 200.465 allows for ordinary rentals, sale-leasebacks, related-party leases, and finance leases, and how to document the decision.
Property Management System Requirements for Federally-Funded Equipment (2 CFR 200.313)
What 2 CFR 200.313 requires for equipment purchased with federal grant funds: the six required elements of a property management system, biennial physical inventory, disposition thresholds, and when the SF-428 form family applies.
Cooperative and Intergovernmental Purchasing Agreements Under 2 CFR 200.318(e)
How 2 CFR 200.318(e) authorizes federally funded institutions to use state, local, and intergovernmental cooperative purchasing agreements, and what still has to be documented to stay compliant.
Government-Furnished Property in University Research Awards: Custodial Responsibilities and Tracking
What 2 CFR 200.312 requires when a federal sponsor furnishes equipment to a university performing a research award: title, recordkeeping, SF-428 annual reporting, and disposition rules — and how this differs from FAR/DFARS government-furnished property in defense contracting.
Time-and-Materials Contract Restrictions Under 2 CFR 200.318(j)
What 2 CFR 200.318(j) requires before a recipient or subrecipient can use a time-and-materials contract on a federal award: a documented determination, a ceiling price, and ongoing cost-control oversight.
NIH Change of Grantee Institution: How to Transfer a Grant When a PI Moves
The operational steps for transferring an active NIH grant when a PI changes institutions: the relinquishing institution’s Form 3734 and equipment obligations, the receiving institution’s Type 7 application, timing, and why training grants and fellowships transfer differently than a standard R01.
Grant Funds Clawback and Recoupment: How and Why Federal Agencies Take Back Awarded Money
How federal agencies recover already-disbursed grant funds through audit findings, termination for cause, or fraud determinations, and how that differs from a routine closeout adjustment.
Managing Currency Exchange-Rate Risk in International Research Grants
How exchange-rate movement affects multi-year international research grants, the budgeting and hedging approaches institutions use to manage it, and how NIH, Horizon Europe, and Wellcome actually treat currency variance in their grant terms.
How to Calculate Indirect Costs (F&A) vs. Direct Costs on a Grant Budget
A step-by-step walkthrough of how to calculate indirect (F&A) costs on a US federal grant budget: computing the Modified Total Direct Cost (MTDC) base under 2 CFR 200.1, applying the negotiated F&A rate, and a full worked numeric example.
Writing a Budget Justification That Survives Allowability Review Under 2 CFR 200
How to write budget justification narratives, line item by line item, that satisfy 2 CFR 200’s allowability, allocability, and reasonableness tests and hold up under pre-award and audit review.
De Minimis Indirect Cost Rate: Who Qualifies and How It’s Calculated
A practical guide to the de minimis indirect cost rate under 2 CFR 200.414(f): eligibility, the current 10% vs. 15% rate split between NIH and other agencies, how to calculate it against Modified Total Direct Costs, and how it differs from a negotiated NICRA rate.
Federal Grant Reporting Requirements: A Guide to What’s Due, and When
A cross-agency orientation to the reports a federal grant recipient owes over an award’s life — performance/progress, financial (SF-425), invention, and closeout reports — with the regulatory citation and deep-dive guide for each.
Pre-Award Costs Under 2 CFR 200.458: What Can Be Charged Before an Award Starts
What 2 CFR 200.458 actually requires for pre-award costs, why the widely-cited 90-day window is agency policy layered on top of the regulation (not text in 200.458 itself), and the institutional risk of spending against an award that hasn’t been issued yet.
FDP Unilateral Amendment: What It Is and When a Pass-Through Entity Can Use One
The Federal Demonstration Partnership publishes both unilateral and bilateral subaward amendment templates. This guide explains the difference, what kinds of changes a pass-through entity can make unilaterally, and when subrecipient signature is required.
Types of Federal Contracts Universities Encounter: FFP, Cost-Reimbursement, and T&M
A university federal contract can be priced firm-fixed-price, cost-reimbursement, or time-and-materials under FAR Part 16 — an orientation to all three, with the deep FFP-vs-cost-reimbursement mechanics and T&M’s FAR 16.6 restrictions covered separately.
Subrecipient Risk Assessment: How Pass-Through Entities Score Subrecipients Before Award
Under 2 CFR 200.332(c), a pass-through entity must evaluate a proposed subrecipient’s risk of noncompliance before making a subaward. This guide covers the four regulatory factors, how institutions turn them into a scored risk tier, and how that tier sets the monitoring plan that follows.
NSF No-Cost Extension: How to Request One
How NSF’s no-cost extension process works: the 12-month grantee-approved extension institutions can authorize themselves, versus an NSF-approved additional extension requiring Program Officer or Grants and Agreements Officer approval, submitted via Research.gov.
NIH No-Cost Extension (NCE): First-Year vs. Second-Year Rules and How to Request One
NIH no-cost extensions run on two tracks: a first, grantee-authorized 12-month extension under expanded authority, and a second or later extension that requires NIH prior approval. This guide covers eligibility, the eRA Commons request process for each, common justifications, and what an NCE cannot be used for.
NIH Indirect Cost Policy: Negotiated F&A Rates, Mechanism-Specific Exceptions, and the 2025 Cap Dispute
NIH indirect cost policy layers several of its own exceptions — flat 8% rates for training grants and foreign components, no F&A at all for individual fellowships — on top of the general 2 CFR 200 negotiated-rate framework, on top of which sits the still-unresolved 2025 proposal for a flat 15% cap.
Resolving Post-Award Issues with NIH Grants
A practical walkthrough of the most common NIH post-award issues — rebudgeting, no-cost extensions, PI/institution transfers, and carryover — what requires NIH prior approval, and whether the Grants Management Specialist or Program Officer handles it.
Faculty Effort Allocation Across Multiple Grants: The 100% Rule, Consistency, and Audit Risk
How to allocate a faculty member’s committed effort across simultaneous federal awards within the 100%-of-institutional-base-salary ceiling, keep certified effort consistent with what was proposed and budgeted, and avoid the overcommitment and uncertified-effort findings auditors flag most often.
Subrecipient Monitoring Checklist: A Pass-Through Entity’s Obligations Under 2 CFR 200.332
What a pass-through entity must do under 2 CFR 200.332: assess subrecipient risk before the subaward, monitor financial and programmatic reports during the period of performance, and follow up on audit findings — with a practical checklist.
Fringe Benefit Rate in Sponsored-Research Budgets: What It Covers and How It’s Applied
The fringe benefit rate recovers an employee’s benefit costs in a sponsored-research budget under 2 CFR 200.431. This guide covers how fringe is negotiated by employee category, how it applies to a salary-capped budget, and walks a full worked example from personnel and effort through fringe, other direct costs, the MTDC base, and F&A to a total-cost figure.
Cost Allocation Methods for Grant Projects
How institutions distribute shared costs, like equipment, staff time, and facility space, across multiple grants and cost objectives in proportion to relative benefit, per 2 CFR 200.405.
NIH RPPR: How to Complete the Research Performance Progress Report
How to complete the NIH RPPR: the three report types, the A-I section table, person-months and Other Support disclosures, eRA Commons routing/recall roles, and a pre-submission checklist.
NIH No-Cost Extension: How to Request One
A step-by-step guide to requesting an NIH no-cost extension: the difference between the automatic first 12-month extension and a prior-approval second extension, who submits it, timing, and common reasons requests are denied.
How an OIG Audit of a Research Grant Works
What triggers a federal agency Office of Inspector General audit of a research grant, how the audit process runs from entrance conference to final report, the findings that recur most in research-institution audits, and how institutions respond with a corrective action plan.
SF-425: The Federal Financial Report Explained
What SF-425 (the Federal Financial Report) covers, when it is due under 2 CFR 200.328, what each section of the form reports, and how it differs from the SF-424 application and the RPPR progress report.
2 CFR 200 Subpart E: The Cost Principles Governing Federal Grant Costs
A deep dive into 2 CFR 200 Subpart E (Sections 200.400-200.475), the Uniform Guidance cost principles governing which costs are allowable, allocable, and reasonable on a US federal research award — including the direct-vs-indirect cost distinction and the selected-items-of-cost catalog.
Sample Letter of Award (Notice of Award): Key Components and What to Check
What a Notice of Award (NoA) is, an illustrative composite sample showing its key fields, and what recipients should verify against the proposal before spending begins.
2 CFR 200 Procurement Standards: §§200.317–200.327 Explained
The current micro-purchase and simplified acquisition thresholds, the five procurement methods, documentation requirements, the procurement conflict-of-interest rule, and the mistakes that actually get institutions cited in a Single Audit under 2 CFR 200 Subpart D (§§200.317-200.327).
NSF OIG: How the National Science Foundation’s Inspector General Works
How NSF’s Office of Inspector General is structured, why it’s independent of NSF, and how its combined audit-and-research-misconduct role under 45 CFR 689 differs from the separate HHS-OIG/ORI split at PHS agencies.
Federal Audit Clearinghouse (FAC): How Single Audit Submission Works on fac.gov
The Federal Audit Clearinghouse (FAC) is where Single Audit reporting packages get submitted and made publicly searchable. GSA has run the FAC on fac.gov since October 2023, replacing the Census Bureau; submission is due the earlier of 30 days after receiving the auditor’s report or nine months after fiscal year-end, per 2 CFR 200.512.
Indirect Cost Rate Mechanics for SBIR Government Contractors
How indirect cost rates actually work on SBIR awards structured as FAR contracts — provisional billing rates, the incurred cost submission, and final rate negotiation — versus the 2 CFR 200 process used for university and nonprofit grants.
2 CFR 200 Subpart A: The Definitions and Acronyms Behind the Uniform Guidance
What 2 CFR 200 Subpart A actually contains: the acronym list at Sec. 200.0 and the formal definitions at Sec. 200.1 (Federal award, non-Federal entity, recipient, subrecipient, pass-through entity) that every other subpart of the Uniform Guidance depends on, and why a single controlled vocabulary matters for resolving audit-finding disputes.
Single Audit Report Example: Inside a Reporting Package’s Structure
A Single Audit “report” is really a multi-part reporting package. This guide walks through each required component — SEFA, auditor opinions, Schedule of Findings and Questioned Costs, corrective action plan, and FAC submission — under 2 CFR 200 Subpart F.
NIH RPPR: A Worked, Filled-In Example
A worked, filled-in example of an NIH RPPR (Research Performance Progress Report), section by section, for a hypothetical Annual RPPR, plus what changes on an Interim or Final report.
NIH Grant Terminations: Grounds, Process, and Appeal Rights
What actually happens when NIH terminates a grant: the four grounds under 2 CFR 200.340, notice and objection rights, how termination differs from non-renewal and expiration, and the NIH/DAB appeal path.
Types of Audit Findings: The 2 CFR 200 Subpart F Taxonomy
A breakdown of the federal-grant audit-finding taxonomy under 2 CFR 200 Subpart F: significant deficiency, material weakness, material noncompliance, and questioned costs, plus what drives each institutional response.
NIH RPPR (Research Performance Progress Report): Types, Sections, and Deadlines
How the NIH Research Performance Progress Report (RPPR) works: the Annual, Final, Interim, and MYF report types, eRA Commons submission roles, required A-I sections, and due-date rules.
What Is Cost Sharing? Mandatory vs. Voluntary Under 2 CFR 200.306
Cost sharing is the portion of a federal award’s total project cost funded from non-federal sources instead of the award itself. This guide explains mandatory vs. voluntary committed cost sharing under 2 CFR 200.306, in-kind vs. cash matching and valuation rules, and why cost sharing is a routine Single Audit finding.
FDP Expanded Clearinghouse: Subrecipient Data, Assurances, and Access
What the FDP Expanded Clearinghouse is, what subrecipient data (audit status, F&A rates, assurances, FCOI) it certifies, who can participate, and how it differs from the separate FDP FCOI Clearinghouse.
Managing Multi-Institutional Research Collaborations
How multi-institutional research collaborations are actually structured: inter-institutional agreements (IIAs), subaward vs. consortium agreements, lead-institution vs. distributed multiple-PI governance, and authorship/credit allocation across institutions.
The False Claims Act in Research Grant Compliance
How 31 U.S.C. §§ 3729-3733 applies to grant certifications, effort reporting, and qui tam suits — with real DOJ settlements and what sponsored-programs offices do to manage the risk.
