CASRAI Dictionary

Author: MCP Service

  • NIH’s Ban on AI-Generated Grant Applications: What NOT-OD-25-132 Requires

    The National Institutes of Health has put research offices on notice: proposals that look like they were written by a machine, and principal investigators who submit an implausible volume of them, will now be treated as a fairness problem rather than a productivity feature. NIH AI policy grant applications is the subject of NOT-OD-25-132, “Supporting Fairness and Originality in NIH Research Applications,” issued 17 July 2025 and effective for applications with due dates on or after 25 September 2025. The notice does two distinct things at once — it restricts the use of generative AI in drafting applications, and it caps the number of applications any one principal investigator (PI) can submit per year — and research administrators need to treat them as two separate compliance obligations, not one.

    What NOT-OD-25-132 Actually Says

    NIH’s position is narrower than “no AI allowed.” The notice states that applications must reflect the original ideas and scientific contributions of the investigators, and that NIH will not accept applications that are substantially developed by AI. That is a materiality threshold, not a blanket prohibition on tools — spell-checkers, reference managers, and light editorial assistance are not the target.

    The stated concern is specific: NIH flags plagiarism, fabricated or non-existent citations, and other misleading content generated by large language models as the practical harms it is trying to prevent, not AI use in the abstract. Applications judged to fall foul of this standard can trigger a research misconduct review and enforcement action, including referral to the Office of Research Integrity, disallowance of costs, or termination of an award already made.

    NIH published the policy as a companion pair: the formal Guide notice (NOT-OD-25-132) and an accompanying Extramural Nexus explainer, “Apply Responsibly,” released two weeks later on 31 July 2025. A supporting FAQ page clarifies edge cases such as how applications are counted and which activity codes are exempt.

    The Six-Application PI Limit, Explained

    The second, less-discussed half of the notice caps submissions. An individual PI or Program Director — including each PI listed on a Multiple PI application — may submit a maximum of six new, renewal, resubmission, or revision applications within a defined NIH Council Round. NIH has said the cap was prompted by evidence that a small number of investigators, aided by AI drafting tools, were submitting dozens of applications in a single round, in some cases reportedly more than 40, straining the peer-review system disproportionately relative to the scientific contribution.

    Council Round Applications counted toward the cap
    2026 Council Round Due dates 25 September 2025 through 7 May 2026
    2027 Council Round Due dates 25 May 2026 through 7 May 2027

    Two activity types are explicitly carved out: T-series training grants and R13 conference grants. The limit applies only to the PI/PD role — an investigator can still appear as a co-investigator, senior/key personnel, or a PI on a subaward across as many applications as the science supports, without those roles counting against their own six-application ceiling.

    • Counts toward the cap: new, renewal, resubmission, and revision applications where the individual is listed as PD/PI or Multiple PI.
    • Does not count toward the cap: T-activity-code training grants, R13 conference grants, and any application where the individual’s role is co-investigator or subaward PI rather than the lead PD/PI.
    • Counting trigger: institutional guidance (e.g., UCSF’s Office of Sponsored Research) indicates an application is counted toward the limit once it passes administrative review, prior to peer review — so late withdrawals after that point may still occupy a slot.

    PIs are responsible for tracking their own running total through eRA Commons; NIH does not promise to intercept a seventh application before submission, and rejection at that stage disrupts a funding cycle an institution cannot easily recover.

    AI Detection and Post-Award Consequences

    The most consequential detail for research offices is timing: NIH’s review for AI-substantiality is not confined to the submission window. The notice makes clear that detection can occur at the post-award stage — after funds have already been drawn down — and that a finding of substantial AI authorship at that point is treated with the same seriousness as post-hoc discovery of plagiarism or fabricated data.

    That reframes the risk calculus for institutions. A proposal that clears peer review and receives an award is not retroactively safe; institutional research integrity offices should treat AI-authorship disclosures and certifications as live documents that could be tested years into a project period, not a one-time submission checkbox.

    Compliance FAQs for Research Offices

    What is NOT-OD-25-132?

    NOT-OD-25-132 is an NIH Guide notice, “Supporting Fairness and Originality in NIH Research Applications,” issued 17 July 2025. It bars grant applications substantially developed by AI and, separately, caps most PIs at six NIH applications per year, effective for due dates from 25 September 2025.

    How many grants can one PI submit to NIH per year?

    A maximum of six new, renewal, resubmission, or revision applications per PD/PI or Multiple PI, counted per NIH Council Round rather than the calendar year strictly. T-series training grants and R13 conference grants are exempt from the count entirely.

    Does NIH ban all use of AI in grant writing?

    No. NIH restricts applications “substantially developed by AI” — content that is not the applicant’s original scientific thinking — rather than incidental editing or drafting assistance. The concern is plagiarism, fabricated citations, and misleading content, not tool use itself.

    What happens if AI use is detected after an award is made?

    NIH can pursue a research misconduct review, refer the case to the Office of Research Integrity, and take enforcement action including disallowance of costs or termination of the award — even after funding has already begun.

    Compliance Steps Before the Next Submission Cycle

    Research offices working toward the 2027 Council Round have a defined window to close process gaps. Practical steps that institutional sponsored-programs and research-integrity functions are adopting:

    • Add an explicit AI-originality certification to internal routing and sign-off forms, distinct from the existing research-misconduct and conflict-of-interest attestations.
    • Track each PI’s running six-application count centrally rather than relying on individual faculty to self-monitor eRA Commons, particularly across multi-department or multi-PI proposals.
    • Flag applications naming the same PI as PD/PI on more than six efforts early in the planning cycle, and confirm which, if any, qualify for the T-code or R13 exemption before assuming a conflict exists.
    • Brief investigators that post-award AI-authorship findings carry the same institutional exposure as post-award data-integrity findings — this is not solely a pre-submission compliance question.
    • Coordinate with departmental research administrators (the audience ARMA, NCURA, and EARMA serve) so that the cap is applied consistently across schools and centres within one institution, since NIH counts at the individual-PI level regardless of departmental structure.

    Implications for the Wider Research Ecosystem

    NOT-OD-25-132 sits inside a broader pattern: funders are converging on the idea that AI-assisted productivity gains in proposal writing are not neutral if they change who gets reviewed and how thoroughly. The six-application cap is, functionally, a peer-review capacity-protection measure as much as an integrity measure — NIH is acknowledging that AI tools changed submission economics faster than its review infrastructure could absorb.

    For research administration more broadly, the notice is also a signal that funder-side AI governance is arriving as binding operational policy, not aspirational guidance, and that institutions without a documented AI-in-proposals policy of their own are now exposed to funder-level enforcement they cannot pre-empt internally. Institutions that build durable certification and tracking workflows now — rather than treating this as a one-off notice to file away — will be better positioned as other US and international funders publish comparable AI-authorship and submission-volume rules over the next funding cycles.

  • AI in Grant Peer Review: How ERC, NIH, UKRI and NHMRC Draw the Line

    Four major funders have now published, or are actively revising, formal rules on AI in grant peer review, and the details differ enough that a reviewer moving between panels could unknowingly breach one funder’s terms while complying with another’s. In March 2026 the European Research Council (ERC) issued new guidelines on AI use in evaluation; the US National Institutes of Health (NIH) tightened its stance on AI-drafted applications from September 2025; UK Research and Innovation (UKRI) maintains a stricter blanket ban that peers expect to loosen; and Australia’s National Health and Medical Research Council (NHMRC) introduces a revised generative-AI policy from 28 April 2026. Research offices drafting or updating reviewer agreements need to track all four.

    How ERC, NIH, UKRI and NHMRC draw the line

    Each funder separates permitted “AI-assisted” support from prohibited “AI-generated” evaluation, but the exact boundary — and the effective date — varies.

    Funder Rule effective AI-assisted (permitted) AI-generated (prohibited)
    ERC 24 March 2026 Language polishing of a reviewer’s own report; general (non-proposal) information searches Summarising proposals, assessing scientific merit, drafting evaluations, uploading any proposal content to external AI systems
    NIH Applications submitted from 25 September 2025 Limited administrative tasks in application preparation Reviewers using generative AI to analyse applications or formulate critiques; applications “substantially developed by AI” are treated as non-original and not reviewed
    UKRI Current policy; Research Funding Policy Group review pending None yet formally sanctioned for reviewers — even AI-assisted grammar checks are currently disallowed Any generative AI use by reviewers or panellists in assessing applications
    NHMRC 28 April 2026 Generative AI to refine clarity or grammar of a reviewer’s own comments Using AI to evaluate, critique or score applications

    A fifth data point is worth noting: the US-based Foundation for Food & Agriculture Research (FFAR) went further still in November 2025, prohibiting reviewers from using AI tools in any capacity during peer review — including refinement of their own comments — on confidentiality grounds. That makes FFAR the strictest outlier against which UKRI’s current position, and NHMRC’s narrower allowance, can be benchmarked.

    • Confidentiality is the universal red line. Every policy reviewed prohibits uploading proposal text, applicant data or reviewer notes into public or third-party AI tools.
    • Non-delegation is the second constant. Scientific merit assessment must remain a human judgement in all four jurisdictions, regardless of how permissive the language-polishing allowance is.
    • UKRI is currently the most conservative of the four, with a sector-wide Research Funding Policy Group review expected to permit limited generative AI use in processing (not scoring) applications while keeping final decisions human-made.

    AI-assisted vs AI-generated: common questions

    Research offices repeatedly ask the same handful of questions when briefing reviewers. The answers below are grounded in the funder documents referenced above.

    What is the difference between AI-assisted and AI-generated peer review?

    AI-assisted review means a human reviewer uses a tool only for mechanical tasks — grammar, clarity, formatting of their own text — while retaining full intellectual authorship of the assessment. AI-generated review means the AI performs part of the evaluative task itself, such as summarising a proposal, scoring merit, or drafting critique content, which every funder surveyed here prohibits.

    Has NIH banned AI in grant peer review?

    Yes. NIH prohibits scientific peer reviewers from using generative AI tools to analyse applications or formulate critiques, a position it has held since June 2023. From 25 September 2025, NIH also treats applications substantially developed by AI as non-original, removing them from review rather than scoring them on merit.

    Can UKRI reviewers use AI to check grammar in their assessments?

    Not currently. UKRI’s existing policy forbids reviewers and panellists from using generative AI for any part of assessment, including language or grammar correction — a stricter line than ERC or NHMRC. A sector-wide funder policy group is expected to revisit this, but any change would still require human-made final decisions.

    When does the NHMRC generative AI policy take effect?

    NHMRC’s revised Policy on Use of Generative Artificial Intelligence in Grant Review takes effect from 28 April 2026. It permits peer reviewers to use generative AI to refine the clarity or grammar of their own comments, but explicitly prohibits using AI to evaluate, critique or score applications.

    Practical reviewer-agreement language for research offices

    Research offices administering panels — whether for an internal seed-fund competition, a co-funded international call, or as a delegated peer-review manager for an external funder — need reviewer agreements that anticipate divergence between funder rules. Three drafting principles reduce risk:

    • Name the prohibited actions explicitly, not just the tool category. A clause banning “AI tools” is weaker than one banning “uploading proposal content, applicant identifiers, or draft scores to any AI system, whether or not the funder’s own policy names that system.”
    • State the confidentiality obligation independently of the AI-use clause. General-purpose AI (GPAI) providers regulated under the EU AI Act’s GPAI obligations, in force since August 2025, may process submitted inputs for model improvement unless expressly excluded, so agreements should require reviewers to confirm no proposal content has been shared with any third-party system, GPAI-regulated or not.
    • Require disclosure, not just prohibition. A short attestation line — “I have not used generative AI to draft, summarise or score any part of this review, and any AI assistance used was limited to language editing of my own original text” — gives research integrity offices an auditable record if a dispute arises.

    Where a funder (such as NHMRC from April 2026) permits limited AI-assisted editing, research offices should still require reviewers to disclose which tool was used and confirm no proposal content was entered into it. This keeps institutional practice defensible even where funder rules differ from one call to the next.

    Implications and outlook

    For institutions running multi-funder portfolios, the practical challenge is less about any single funder’s rule and more about reviewer confusion across simultaneous panels. A reviewer serving both an ERC panel and a UKRI-funded call in the same month operates under materially different AI permissions for the same underlying task. Research offices should treat funder AI policies as living documents — ERC’s and NHMRC’s 2026 updates both followed roughly a year or more after their organisations’ initial public positions on AI, suggesting further revision is likely as reviewer behaviour and AI capability both evolve.

    The direction of travel across all four funders is convergence on two non-negotiables — confidentiality of proposal content and non-delegation of scientific judgement — even as the permitted margin for administrative AI assistance slowly widens. Research offices that build reviewer agreements around those two constants, rather than around any single funder’s current wording, will need fewer rewrites as UKRI’s pending policy shift and any subsequent NIH or ERC revisions land through 2026 and beyond.

    For related terminology used across funder and publisher AI-governance documents, see the CASRAI research dictionary, and for broader institutional process guidance visit the research administration resource hub.

  • AI in Research Administration: Where It’s Actually Deployed

    Most coverage of artificial intelligence in higher education still centres on the classroom — chatbots writing essays, detectors chasing them. Less visible, but arguably more consequential for research offices, is AI in research administration: the back-office layer of proposal budgeting, compliance screening and post-award reporting that keeps federally and privately funded research compliant and auditable. That layer is where AI is quietly moving from pilot to production in 2026, and the evidence — not the marketing copy — shows a narrower, more cautious footprint than headlines suggest.

    This is not a piece about generative AI and authorship integrity, disclosure norms, or research misconduct detection in manuscripts — those questions sit in a separate, already well-documented debate. This is about the administrative machinery: proposal-budget checking, risk-based compliance review, contract redlining and financial reporting inside research offices, sponsored-programmes units and grants-management systems.

    Where AI Is Actually Being Deployed

    The clearest signal comes from a March 2026 Ithaka S+R report, funded through the National Science Foundation’s GRANTED programme (grant #2437518), which convened two workshops — one at Montclair State University (31 participants, 13 institutions) and one at Chapman University (32 participants, 13 institutions) — specifically to catalogue how research administration software and AI tools are being used inside research offices. The findings map closely onto three workflow areas:

    • Pre-award proposal and budget checking. Institutions are using AI to review draft proposals and budgets for items that will trigger downstream review — facilities requirements, human-subjects protocols, or budget lines inconsistent with a sponsor’s rules.
    • Risk-based compliance screening. AI is used as a first-pass filter that flags transactions, contract clauses, or expenditures for human review rather than replacing that review — described by workshop participants as “an extra layer” that directs attention, not a decision-maker.
    • Contract and reporting automation. Redlining of routine contract language, drafting of progress narratives, and identification of funded projects with commercialisation potential are the most cited post-award use cases.

    Two concrete examples illustrate the pattern at very different institutional scales. Southern Utah University, a smaller teaching-focused institution, built a budget-availability report that automatically flags high-risk expenditures for review — a narrow, operationally specific tool rather than a platform. At the University of California San Diego, a large research-intensive institution, the contracts and grants office is running risk-based proposal review to identify projects needing facilities or IRB attention, and has automated non-disclosure-agreement redlining in a way staff estimate cuts drafting time by roughly 70 percent.

    Workflow stage AI use case Maturity in 2026 Reported example
    Pre-award Proposal/budget risk flagging Early production UCSD risk-based proposal review
    Pre-award Funding-opportunity matching Experimental Faculty-to-grant matching pilots
    Compliance Contract clause / NDA redlining Early production UCSD NDA redlining
    Compliance Expenditure anomaly flagging Pilot Southern Utah University budget-availability tool
    Post-award Progress-report drafting Experimental Institution-reported pilots, Ithaka S+R 2026
    Institution-wide Policy Q&A chatbot for staff Early production UCSD TritonGPT; Emory ORAgpt proof-of-concept

    Evidence From the Field: What Institutions Report

    Two enterprise-level projects sit ahead of the field. TritonGPT, developed at UC San Diego and trained on institutional policy documents, has been available to the campus community since 2023 and is now offered as software-as-a-service to other institutions. At the University of Idaho, the NSF GRANTED-funded AI4RA initiative is building open-source tools for research administrators. At the system level, the California State University system ran a 94,000-response AI sentiment survey — described as the largest of its kind — to set baseline metrics before committing to further rollout.

    These are not isolated enthusiasm projects. The Council on Governmental Relations (COGR) has documented that the U.S. federal government issued more than 200 new or revised policies affecting research administration over the preceding ten years — a compliance burden that is the actual driver behind AI adoption, not novelty. Emory University’s sponsored-programmes office built a proof-of-concept generative AI chatbot, reported by SRA International in May 2025, intended to give research administrators instant, policy-grounded answers rather than requiring them to search static guidance documents.

    Answer-First Q&A

    What is AI actually used for in research administration?

    Institutions report using AI mainly for risk-based screening: flagging proposal budgets, contract clauses, or expenditures that need human review, plus drafting routine reports and answering staff policy questions. It is deployed as a triage layer, not as an autonomous decision-maker in compliance-sensitive workflows.

    Is AI reliable enough for research compliance work?

    Not on its own. Workshop participants in the Ithaka S+R study described current tools as error-prone for high-stakes compliance decisions, so institutions keep a human reviewer in the loop and use AI outputs as a prioritisation signal rather than a final determination.

    What is electronic research administration (eRA) software?

    Electronic research administration (eRA) software centralises pre-award proposal development, post-award financial tracking, IRB/IACUC compliance management, and reporting in one system. Vendors including Cayuse, InfoEd Global and Streamlyne are now embedding AI features into these existing platforms rather than institutions building AI tools separately.

    Will AI replace research administrators?

    Current evidence points the other way. Institutions describe AI as freeing staff time for relationship-building and strategic work, while raising a genuine concern: if entry-level document review and compliance checks are automated away, the profession may lose the training ground that builds administrator judgement over time.

    What Remains Experimental — and Why

    Effort-report anomaly detection — using AI to flag inconsistencies in how research staff certify time charged to federal awards — is frequently proposed as a logical extension of risk-based screening, but publicly documented institutional deployments remain scarce as of mid-2026. This gap matters: effort reporting sits inside some of the most tightly regulated financial-compliance territory in federally sponsored research, and institutions appear to be moving deliberately rather than rushing tools into that specific workflow.

    Three barriers recur across every institution surveyed in the Ithaka S+R workshops:

    • Data governance. Fragmented, inconsistent institutional data undermines AI output quality, and grant proposals routinely contain data covered by HIPAA, export-control rules, or pre-publication intellectual property.
    • Fragmented adoption. Most institutions have not articulated an institution-wide AI strategy for research administration; use is left to individual staff discretion, producing uneven, hard-to-scale experimentation.
    • Trust. Faculty scepticism about whether proposal or compliance data will be used to train external vendor models directly affects whether research administrators can deploy AI tools without damaging working relationships they depend on.

    Implications for Institutions and the Profession

    The practical pattern for institutions considering AI in grants management and compliance workflows is narrower and more disciplined than vendor marketing implies: start with a specific, bounded use case — budget flagging, contract redlining, a policy-guidance chatbot — evaluate it against defined return-on-investment questions, and keep a human reviewer accountable for the final determination. The institutions cited above succeeded by treating AI as an attention-directing layer inside existing research administration workflows, not as a replacement for the judgement that compliance work requires.

    For the broader field of research management and administration, the open question the Ithaka S+R researchers themselves flag is workforce development: if AI absorbs the entry-level document review that has historically trained new research administrators, institutions will need to redesign how professional judgement is built, not just how workloads are reduced. Organisations such as NCURA, SRA International and NORDP are already the venues where this cross-institutional knowledge-sharing is happening, ahead of any formal standard for AI use in the field.

    CASRAI’s own coverage of research administration software categories and standards tracks how eRA platforms are evolving as AI features are absorbed into existing pre-award, post-award and compliance modules — the practical mechanism by which most institutions will encounter AI in this space, rather than through bespoke in-house builds.

  • 2 CFR 200 Cost Principles: What Changes Under the 2026 OMB Rule

    On 29 May 2026, the US Office of Management and Budget (OMB), joined by federal award-making agencies, published a proposed rule in the Federal Register substantially rewriting 2 CFR Part 200 — the government-wide Uniform Guidance governing federal grants and cooperative agreements. Inside that broader overhaul sits a narrower, technical change: a rewrite of the 2 CFR 200 cost principles in Subpart E, the section that decides which costs a university, hospital, non-profit, or state agency may lawfully charge to a federal award. For research administrators, the operative question is not whether reporting formats change — it is whether costs an institution has always treated as allowable will still be allowable after the proposed effective date of 1 October 2026.

    What the 2 CFR 200 Cost Principles Actually Require

    Subpart E of 2 CFR Part 200 sets out the framework recipients must apply when deciding whether a cost can be charged — directly or indirectly — to a federal award. Under §200.403 and related sections, a cost is only allowable if it is:

    • Reasonable — it does not exceed what a prudent person would incur under the same circumstances, judged against market prices, sound business practice, and award terms.
    • Allocable — it is incurred specifically for the award, or benefits the award and other work in proportions that can be reasonably estimated.
    • Consistently treated — like costs must be treated alike across federally and non-federally funded activities.
    • Conforming — the cost must comply with limitations in Subpart E itself, in agency-specific implementations such as 2 CFR Part 300 (HHS’s codification of the Uniform Guidance), or in the award’s terms.

    Subpart E also lists over 50 “selected items of cost” — from advertising to travel, equipment, and compensation — each with its own rule. This is the list the 2026 proposed rule edits most directly.

    The 2026 OMB Proposed Rule: What Changes for Allowability

    OMB frames the May 2026 proposal around three objectives: improving transparency, accountability, and oversight of federal funds; clarifying the regulatory status of the 2 CFR text as an OMB rule; and reducing recipient burden. In Subpart E, these goals pull in different directions — some provisions loosen documentation, others tighten what can be charged at all. Comments are due 13 July 2026, ahead of a proposed effective date of 1 October 2026, the start of federal fiscal year 2027.

    The most consequential Subpart E changes in the current draft include:

    • Publication costs would become unallowable unless required by statute or approved in advance by the awarding agency case-by-case.
    • Advertising and public relations costs would become presumptively unallowable, narrowing existing exceptions for recruitment and procurement.
    • Conference attendance costs would only be allowable where expressly approved by the agency and written into award terms.
    • Fundraising and investment management costs would require prior written agency approval rather than the current general prohibition with narrow carve-outs.
    • Fixed-amount awards and subawards would be eliminated; OMB argues they “limit transparency and hinder effective oversight” versus cost-reimbursement structures.
    • A related change to §200.300 (Statutory and National Policy Requirements) would bar federal funds from being used to “fund, promote, encourage, subsidize, or facilitate” DEI or DEIA policies found to violate federal anti-discrimination law — adjacent to, but legally distinct from, the Subpart E allowability tests.

    Despite Executive Order 14332 directing OMB to curb indirect cost recovery on discretionary grants, the proposal does not alter the indirect-cost-rate negotiation system: FY2026 appropriations riders required specified agencies to keep applying negotiated rates as they stood in FY2024. That leaves the 15% de minimis indirect cost rate — raised from 10% in the October 2024 revision, alongside a $10,000 equipment threshold (up from $5,000) and a $1,000,000 Single Audit threshold (up from $750,000) — unchanged for now.

    Allowable vs Unallowable Costs: Current Guidance vs the 2026 Proposal

    The table below summarises how treatment shifts for the categories most affected by the 2026 draft. Treat this as directional, not final — the rule remains open for comment and can change before any effective date.

    Cost category Current treatment (2024 Uniform Guidance) Proposed treatment (2026 draft rule)
    Publication costs Generally allowable as a direct or indirect cost Unallowable unless statute-required or agency pre-approved
    Advertising / public relations Allowable for specified purposes (recruitment, procurement, outreach) Presumptively unallowable; narrow exceptions only
    Conference attendance Allowable if reasonable, necessary, and documented Allowable only with express prior agency approval in award terms
    Fundraising / investment management Generally unallowable, with limited carve-outs Requires prior written agency approval
    Fixed-amount awards Available as alternative to cost-reimbursement awards Eliminated on transparency grounds
    Indirect cost (de minimis) rate 15%; agencies barred from imposing a lower rate absent statute Unchanged pending FY2026 appropriations riders

    Cost Principles: Direct Answers to Common Questions

    What are the 4 cost principles?

    The four cost principles applicable to sponsored awards under 2 CFR 200 are that costs must be reasonable, allocable, allowable, and consistently treated. These tests apply not only to federal funds but also to any cost share or in-kind contribution tied to the award.

    What are the three elements of 2 CFR Part 200?

    2 CFR Part 200 combines three components in one regulation: Uniform Administrative Requirements for pre- and post-award management, Cost Principles in Subpart E governing allowability, and Audit Requirements in Subpart F, which sets the Single Audit threshold and reporting obligations.

    What is the 2 CFR 200 standard?

    2 CFR Part 200, commonly called the Uniform Guidance, is the OMB-issued, government-wide rulebook for federal financial assistance. It prescribes how awards are made, how recipients must account for funds, how costs must be treated, and when audits are required — applied across nearly all federal grant-making agencies.

    Under what circumstances does 2 CFR 200 consider a cost reasonable?

    A cost is reasonable if it does not exceed what a prudent person would incur under the same circumstances at the time the spending decision was made. Reviewers weigh market prices, sound business practice, award terms, and deviation from established institutional policy.

    Implications for Research Administrators and Institutions

    Institutions should not wait for a final rule to begin preparing:

    • Audit PI-facing guidance. Flag any internal policy or budget template that assumes automatic allowability of conference travel, publication charges, or advertising spend before 1 October 2026.
    • Submit comments by 13 July 2026. The 45-day comment period is the main channel through which universities, hospitals, and non-profits — often via associations such as COGR, NCURA, or SRAI — can flag unintended compliance burdens before finalisation.
    • Distinguish Subpart E from §200.300. The DEI/DEIA restriction sits in statutory and national policy requirements, not the cost-allowability tests in Subpart E, and follows a different legal standard and appeal pathway.

    These distinctions matter for the broader research administration compliance function, where allowability determinations increasingly intersect with award terms, indirect cost negotiation, and audit preparation. Grant-compliance terminology used throughout this analysis — allowability, allocability, de minimis rate — is catalogued alongside related research-integrity and funding terms in the CASRAI Dictionary.

    What Happens Next

    The 2 CFR 200 cost principles have changed before — the October 2024 revision raised the de minimis indirect cost rate and equipment threshold — and they are set to change again. What distinguishes the 2026 proposal is its narrower target: rather than adjusting thresholds, it tightens the allowability tests themselves for specific cost categories, shifting several from “generally allowable” to “allowable only with prior written agency approval.” Until the comment period closes and OMB issues a final rule, institutions should treat the current Subpart E text as controlling while building the internal review processes the proposal will likely require. For most research offices, the practical impact will be measured in how many budget lines now need agency sign-off before they can be spent.

  • Sponsored Research Administration: A Glossary for New Research Administrators

    Every research administrator remembers the first week: a proposal deadline, an unfamiliar acronym in every email, and a sponsor budget template that assumes vocabulary nobody has explained yet. Sponsored research administration is the institutional function that turns externally funded research proposals into compliant, well-managed awards — and its terminology is not decorative. Getting a definition wrong on a budget justification or an effort report can trigger an audit finding months later. This glossary sets out the core terms a new administrator needs on day one, grounded in how US Uniform Guidance (2 CFR 200), UKRI, and Horizon Europe actually use them.

    What Is Sponsored Research Administration?

    Sponsored research administration is the set of institutional processes that manage externally funded research from proposal through closeout. “Sponsored” distinguishes this funding from an institution’s own discretionary research budget: the money comes from a sponsor — a federal agency, foundation, industry partner, or supranational funder such as the European Commission — under a formal agreement with binding terms and conditions.

    The function typically sits inside an office of sponsored programs or grants and contracts office, where research administrators act as connective tissue between principal investigators, sponsors, and the institution’s finance, legal, and audit functions.

    Research administration is a distinct professional field with its own bodies: NCURA (National Council of University Research Administrators) in the US, EARMA (European Association of Research Managers and Administrators), ARMA (Australasian Research Management Society), and the global umbrella body INORMS — each publishing glossaries and competency frameworks new administrators can use to benchmark their learning.

    The Sponsored-Project Lifecycle: Pre-Award and Post-Award

    Almost every glossary term maps to one of two lifecycle phases. Understanding which phase a term belongs to is often more useful for a new administrator than memorising the definition in isolation.

    • Pre-award covers everything before a sponsor issues funding: identifying opportunities, developing budgets, routing internal approvals, and submitting the proposal.
    • Post-award covers everything after the award is issued: setting up accounts, monitoring spending, certifying effort, filing reports, and closing the project out.
    Phase Typical activities Key terms in play
    Pre-award Proposal development, budget preparation, compliance review, sponsor guideline checks, submission Award, sponsor, cost share, direct costs
    Post-award Award setup, expenditure monitoring, subrecipient monitoring, effort certification, progress reporting F&A, effort certification, no-cost extension
    Closeout Final financial reporting, property disposition, final invoicing, records retention Closeout, final invoice, record retention

    Some institutions split pre-award and post-award into separate teams; others assign one administrator across the full lifecycle. Both models exist across US, UK, and European institutions, and the terminology below applies regardless of structure.

    Core Glossary: Terms Every New Research Administrator Should Know

    These are the terms that appear most frequently in sponsor guidelines, institutional policy, and day-to-day correspondence during a new administrator’s first year.

    • Award — the formal notice from a sponsor confirming a proposal has been funded, together with the binding terms and conditions governing how the money may be spent.
    • Sponsor — the funding organisation: a federal or national agency, a foundation, industry, or a supranational programme such as Horizon Europe.
    • Principal Investigator (PI) — the researcher with primary scientific and programmatic responsibility for the project, typically accountable to the sponsor for its conduct.
    • Direct costs — expenses specifically identifiable with a particular project, such as salaries, equipment, and travel directly attributable to the funded work.
    • Facilities and Administrative (F&A) costs — also called indirect costs or overhead; the expenses an institution incurs to support research broadly (buildings, utilities, central administration) that cannot be charged directly to one project. In the US, F&A rates are negotiated with a cognizant federal agency under the Uniform Guidance at 2 CFR 200.
    • Cost share (or matching) — the portion of project costs not covered by the sponsor. Mandatory cost share is a condition of the award; voluntary committed cost share is offered in the proposal but, once accepted, becomes equally binding.
    • Effort certification — a compliance process, required under 2 CFR 200.430 for US federal awards, confirming that salary charged to a project reflects the actual time an individual spent working on it.
    • Subrecipient / subaward — an organisation receiving a portion of the sponsored funding to carry out a defined part of the project’s scope, itself subject to monitoring by the prime recipient institution.
    • No-cost extension — an extension of a project’s end date, granted without additional sponsor funding, to complete the originally approved scope. Most US federal agencies permit institutions to approve one no-cost extension of up to 12 months under expanded authorities.
    • Closeout — the formal process of finalising a project: final financial and technical reports, expenditure reconciliation, and disposal of sponsor-funded equipment per the award terms.

    Grant Administration vs Grant Management

    New administrators often treat both phrases as synonyms — and in casual use, they usually are. But the terms carry a genuine distinction most onboarding material skips. Research administration (and its narrower cousin, sponsored programs administration) is typically used from the recipient institution’s perspective: how a university, hospital, or institute manages the funding it receives.

    Grant management is used more broadly, often from the funder’s perspective: how a foundation or agency administers its portfolio of outgoing grants and tracks compliance across grantees. UK charitable funders frequently use “grant management” in this funder-side sense, while UKRI and the research councils use “research administration” or “grants and contracts” for the recipient-side function. Knowing which side of the relationship a document is written from resolves most of the apparent inconsistency.

    Common Questions from New Research Administrators

    What is sponsored research administration?

    Sponsored research administration is the institutional function that manages externally funded research from proposal submission through award closeout. It spans pre-award activities such as budgeting and submission, and post-award activities such as compliance monitoring and reporting, ensuring projects meet sponsor terms and institutional policy.

    What is the role of a research administrator?

    A research administrator supports investigators through proposal preparation, budget development, and compliance review, then manages the awarded grant or contract through spending, reporting, and closeout. The role bridges researchers, sponsors, and institutional offices including finance, legal, and compliance.

    How do you become a research administrator?

    Most research administrators enter the profession from finance, project-management, or academic-support backgrounds rather than a dedicated degree route. Professional bodies including NCURA, EARMA, ARMA, and INORMS offer certificate programmes and community-recognised credentials that formalise skills learned on the job.

    Why Terminology Precision Matters

    Imprecise terminology is not cosmetic — it has direct compliance and financial consequences. Confusing mandatory cost share with voluntary committed cost share can leave an institution under-reporting a binding obligation, and treating F&A as a negotiable line item rather than a federally negotiated rate can misstate a budget before it reaches a sponsor.

    Effort certification errors are a recurring federal audit finding precisely because the underlying concept — that certified effort must reflect actual work performed, not budgeted intent — is easy to state and easy to get wrong in practice. New administrators who internalise precise definitions early avoid the costliest category of error: one that surfaces only at audit, long after the relevant staff have moved on.

    For institutions spanning US, UK, and EU funding environments, shared vocabulary matters even more: a research administration office managing both NIH awards and Horizon Europe grants must translate between US-specific terms like “no-cost extension” and the amendment-request processes used by European funders, without losing the underlying compliance intent.

    Building Fluency as the Profession Grows

    Sponsored research administration is professionalising quickly. Certificate programmes, competency frameworks from NCURA and EARMA, and growing recognition of research administration as a distinct career path — rather than an administrative afterthought — point toward a field with rising expectations for precise, shared terminology.

    For a new research administrator, fluency in these terms is not academic: it is the difference between a clean proposal budget and a rejected one, a routine effort report and an audit flag, a smooth closeout and a delayed final payment. Treat this glossary as a starting reference, not a substitute for institutional policy — always confirm current thresholds and rates against your own sponsor’s current guidelines, since these are periodically revised.

    CASRAI’s broader research administration resources and dictionary of standards terminology extend this glossary into adjacent areas, including researcher identification, funder metadata, and contribution reporting standards that increasingly intersect with sponsored-project compliance.

  • Electronic Research Administration: What to Evaluate in 2026

    What electronic research administration actually means

    Electronic research administration (commonly abbreviated ERA, and sometimes called eRA) refers to the digital systems and workflows that universities, hospitals, and research institutes use to manage the full lifecycle of sponsored research — from identifying a funding opportunity through proposal submission, award negotiation, compliance monitoring, and financial closeout. The term covers both the specific federal touchpoints, such as the US National Institutes of Health’s eRA Commons and ASSIST systems, and the broader category of institutional research administration software that sits between researchers, sponsors, and finance offices.

    Most research-intensive institutions no longer run these processes on spreadsheets and shared drives. They run them through a dedicated electronic research administration system, or a stack of interoperable modules, because sponsors themselves have moved to electronic submission. Grants.gov, the UK’s UKRI Funding Service, and Horizon Europe’s portal all require electronic workflows on the sponsor side; institutional ERA platforms exist largely to feed proposals into — and pull award data back out of — those sponsor systems without duplicate manual entry.

    Core modules: pre-award, post-award, compliance, effort reporting

    Despite different vendor branding, mature ERA platforms converge on a broadly consistent set of functional modules. The table below summarises what each typically covers and where it interacts with external systems.

    Module What it typically covers External touchpoints
    Pre-award Funding-opportunity discovery, proposal development, budget building, internal sign-off routing Grants.gov, UKRI Funding Service, sponsor portals
    Post-award Award setup, budget tracking, subaward management, financial reporting to sponsors Institutional finance/ERP systems
    Compliance Conflict-of-interest disclosure, IRB and IACUC protocol tracking, export-control screening, foreign-component disclosure Institutional COI registers, ORCID iDs
    Effort reporting Certifying personnel time charged to sponsored awards against actual effort HR/payroll systems, 2 CFR 200.430
    Analytics/reporting Portfolio dashboards, proposal-to-award conversion, audit-readiness reporting Institutional data warehouses

    Few institutions run all five modules from a single vendor. Chief research officers most often report assembling a stack — a proposal-routing tool from one vendor, a dedicated compliance or effort-reporting module from another — connected through system-to-system integrations rather than buying one suite outright. That reality should shape how any evaluation is scoped: interoperability matters as much as feature breadth.

    Why Uniform Guidance and audit scrutiny are reshaping ERA requirements

    US institutions receiving federal research funding operate under the Office of Management and Budget’s Uniform Guidance (2 CFR Part 200). OMB’s 2024 revisions to that guidance — effective for federal awards issued on or after 1 October 2024 — raised the Single Audit expenditure threshold from $750,000 to $1,000,000 and increased the de minimis indirect cost rate available to institutions without a negotiated rate from 10% to 15%. Both changes alter what an ERA system needs to track and report, and by when.

    • A higher Single Audit threshold shifts more institutions toward risk-based, targeted monitoring rather than a full annual audit — which means ERA compliance modules need to surface exception-based flags, not just generate end-of-year reports.
    • The revised de minimis rate changes how budget and indirect-cost calculations should populate proposal templates by default.
    • Effort reporting remains a perennial audit focus area under 2 CFR 200.430, and reviewers increasingly expect systems to certify effort against documented time-and-attendance data rather than after-the-fact estimates.

    Outside the US, UK and EU institutions face parallel pressure: UKRI’s move to its unified Funding Service and Horizon Europe’s stricter foreign-funding disclosure rules both push institutions toward systems that can evidence compliance on demand rather than reconstruct it retrospectively. An ERA platform selected in 2026 needs to be configurable against a moving regulatory baseline, not just the rules in force at implementation.

    A buyer’s framework: what to evaluate before selecting a platform

    Selection committees — typically a chief research officer, sponsored-programs staff, IT, and finance — should evaluate candidate platforms against criteria that go beyond a feature checklist:

    • Configuration versus customisation. Configurable, vendor-supported systems require less internal IT investment but less bespoke fit; heavily customised systems demand ongoing internal development capacity and are harder to keep current when a vendor ships updates.
    • Audit and compliance readiness. Ask vendors to demonstrate exception-based compliance flagging (COI, effort variance, subrecipient risk), not only static reports generated after the fact.
    • Interoperability. Confirm documented integrations with sponsor systems (Grants.gov, eRA Commons, UKRI Funding Service), identity systems (ORCID), and the institution’s own ERP/HR platforms.
    • Total cost of ownership. Homegrown and heavily customised builds frequently carry hidden maintenance costs beyond the initial development estimate; request a multi-year cost breakdown, not just licence price.
    • Vendor stability and support. Research administration software has consolidated significantly through vendor mergers and rebrands over the past decade; ask about implementation timelines, support SLAs, and product roadmap commitments in writing.

    What is electronic research administration?

    Electronic research administration is the use of digital systems to manage the sponsored-research lifecycle — proposal development, award setup, compliance tracking, and financial reporting — in place of paper-based processes. It replaces manual routing and signatures with system-based workflows that connect directly to sponsor submission portals such as Grants.gov.

    What does a research administrator do?

    A research administrator develops and oversees research proposals, awards, and financial transactions on behalf of an institution and its principal investigators. Core duties include budget development, compliance monitoring, and maintaining records that satisfy both institutional policy and sponsor requirements — increasingly through an electronic research administration system rather than paper files.

    What is the difference between eRA and NIH?

    eRA (the NIH’s Electronic Research Administration platform, including eRA Commons and ASSIST) is the online interface through which grant applicants, grantees, and NIH staff exchange administrative information about federal grants. NIH is the funding agency itself; eRA is one agency’s specific electronic system, not a synonym for the broader ERA software category institutions purchase.

    What are ERA systems?

    ERA systems are institutional software platforms — commercial or, less commonly, homegrown — that manage sponsored-research workflows end-to-end. They typically combine pre-award, post-award, compliance, and effort-reporting modules, and connect to external sponsor and identity systems such as Grants.gov and ORCID.

    Implications for institutions, funders, and publishers

    For institutions, the practical implication of tighter Uniform Guidance thresholds and rising audit scrutiny is that ERA selection is no longer purely an IT or finance-office decision — it is a compliance-risk decision that belongs on the chief research officer’s desk. Systems chosen primarily on price or user-interface polish, without a documented compliance-flagging capability, risk becoming an audit liability rather than an efficiency gain.

    For funders and publishers, the growth of ERA adoption strengthens the case for standardised metadata at the point of proposal and award creation — identifiers such as ORCID iDs and the Research Organization Registry (ROR) reduce downstream reconciliation work when award data eventually needs to map to publications, contributor roles, and institutional affiliations. Professional bodies including NCURA, ARMA, EARMA, and INORMS have each published guidance and community benchmarking on ERA adoption, reflecting how central this tooling decision has become to the research-administration profession globally.

    Outlook: ERA selection as a 2026 strategic priority

    The direction of travel is clear: sponsors are tightening disclosure and audit expectations at the same time as institutions face budget pressure to do more with fewer administrative staff. An ERA platform that cannot demonstrate compliance readiness against a moving regulatory baseline — and that cannot interoperate cleanly with sponsor and identity systems — will struggle to justify its cost within two to three budget cycles. Institutions evaluating platforms in 2026 should treat the selection process as an ongoing compliance investment rather than a one-off procurement exercise, revisiting vendor roadmaps annually against the next round of Uniform Guidance and sponsor-portal changes.

    Institutions building out their research administration function more broadly can also consult CASRAI’s research administration resources and the CASRAI Dictionary for grounded definitions of the compliance and reporting terms that ERA systems are built to track.

  • Pre-Award vs Post-Award Research Administration: Where Compliance Risk Concentrates

    Every sponsored-research office eventually asks the same operational question: where, exactly, does an audit finding get born? Pre-award research administration and post-award research administration are often treated as a single continuous job description, but they carry very different compliance profiles. Under the Office of Management and Budget’s Uniform Guidance (2 CFR 200), the two phases are governed by overlapping but distinct subparts, and institutions that blur the boundary tend to discover the gap only when a federal auditor draws attention to it.

    This guide separates the two functions, maps the specific 2 CFR 200 provisions most associated with audit findings, and flags what changed when OMB’s most recent revision took effect.

    Pre-award vs post-award: where the line falls

    Pre-award activity covers everything that happens before an institution accepts a sponsor’s terms. It is proposal-facing rather than transaction-facing, and its compliance burden is concentrated in representations made to the sponsor rather than in ongoing financial stewardship.

    • Identifying and matching funding opportunities to investigator plans
    • Budget justification and application of institutional/federal indirect cost rates
    • Compliance screening — conflict-of-interest disclosure, human/animal subject clearances, export control review
    • Internal routing, sign-off, and proposal submission
    • Award negotiation and formal acceptance of terms

    Post-award administration begins the moment an award account is set up and runs through closeout. This is where the volume and complexity of federal financial transactions live, which is also why post-award research administration generates a disproportionate share of Single Audit findings.

    • Award and general ledger account setup
    • Ongoing financial compliance monitoring — allowability, allocability, and reasonableness of costs
    • Effort certification and personnel cost justification
    • Subrecipient monitoring on any pass-through funds
    • Interim and final financial and progress reporting
    • Project closeout, equipment disposition, and unused-funds reconciliation

    Bodies such as research administration professional associations — ARMA in the UK, NCURA in the US, and EARMA across Europe — increasingly teach pre-award and post-award as a connected lifecycle rather than two silos, precisely because handoff gaps between the two are where compliance exposure accumulates.

    The compliance risk heatmap

    Not every task carries equal audit exposure. Mapping common research-administration tasks against the Uniform Guidance provisions auditors cite most often produces a practical heatmap for prioritising internal review effort.

    Phase Task Governing 2 CFR 200 provision Typical audit-finding risk
    Pre-award Budget development / indirect cost application Subpart E — Cost Principles Low–Medium
    Pre-award Conflict-of-interest and subject-protection clearance §200.112, institutional policy Medium
    Post-award Procurement of goods/services on federal funds §§200.317–200.327 High
    Post-award Subrecipient monitoring §§200.331–200.333 High
    Post-award Internal controls over federal expenditure §200.303 High
    Post-award Effort certification / salary charging Subpart E, Compensation Medium–High
    Post-award Financial and progress reporting timeliness §§200.328–200.329 Medium
    Post-award Closeout and equipment disposition §§200.344–200.345 Low–Medium

    The pattern is consistent across institutional Single Audits: pre-award weaknesses tend to surface as proposal-accuracy or disclosure gaps, while post-award weaknesses — inadequate subrecipient monitoring, undocumented internal controls, and procurement shortcuts — account for the majority of significant deficiencies reported to cognizant agencies. That imbalance is exactly why post-award teams typically carry larger headcount relative to transaction volume, even though pre-award work is more visible to investigators.

    The Uniform Guidance is changing

    OMB’s most recent revision to 2 CFR 200 took effect for federal awards issued on or after 1 October 2024, and it directly reshapes several of the risk areas above. Institutions still operating on pre-2024 assumptions are the ones most likely to generate findings against the revised text.

    • The Single Audit expenditure threshold rose from $750,000 to $1,000,000, removing some smaller institutions from mandatory audit scope but concentrating audit attention on larger, more complex programmes.
    • The de minimis indirect cost rate available to entities without a negotiated rate agreement rose from 10% to 15% of modified total direct costs.
    • The equipment and capital-asset capitalisation threshold rose from $5,000 to $10,000, changing what must be separately tracked and reported at closeout.

    Further clarifying guidance and agency-specific implementation notes continue to be issued as sponsors align their own policy manuals with the revised text, which means the compliance target for both pre-award and post-award teams is still moving. Research offices that update proposal templates and account-setup checklists only once, at the point of the original 2024 change, risk drifting out of alignment as agencies finish rolling out their own interpretations.

    Common questions on pre-award and post-award risk

    What is pre-award research administration?

    Pre-award research administration is the set of institutional functions that support a project from funding search through award acceptance — matching opportunities, building compliant budgets, screening for conflicts of interest, and routing proposals for internal sign-off before submission to a sponsor.

    What is the pre-award process?

    The pre-award process runs from identifying a funding opportunity through formal award acceptance. It typically includes proposal development, budget justification, internal institutional review, submission to the sponsor, and negotiation of final award terms before the account is established.

    What is a pre-award?

    A pre-award refers to the preparatory documentation and approvals — intent-to-apply forms, budget justifications, compliance certifications — completed before a sponsor formally commits funding. These records establish the institutional and regulatory basis the eventual award will be managed against.

    What skills do you need to be a research administrator?

    Research administrators need working knowledge of sponsor and federal regulations (including the Uniform Guidance), budget and financial analysis skills, attention to procedural detail, and the ability to translate technical compliance requirements into plain guidance for investigators.

    Implications for research offices

    The practical takeaway is not that pre-award compliance is unimportant — a flawed conflict-of-interest disclosure or an unallowable cost baked into a budget justification can still trigger scrutiny. The takeaway is that sponsored research administration teams should weight their internal review and training investment toward where findings actually concentrate: procurement, subrecipient monitoring, and documented internal controls in the post-award phase.

    Institutions that separate “grant administration” from “grant management” organisationally sometimes reproduce the same handoff risk internally — pre-award teams hand a fully compliant proposal to post-award teams who inherit responsibility for terms they did not negotiate. A shared risk register, reviewed jointly across both functions at account setup, closes that gap more reliably than siloed checklists. Institutional glossaries and shared reference material — see CASRAI’s research administration glossary — help standardise the terminology both teams use when escalating a compliance question.

    Looking ahead

    As OMB continues to refine implementation guidance around the 2024 Uniform Guidance revision, the boundary between pre-award and post-award compliance work will keep shifting rather than settling. Research offices that treat the two phases as a connected risk chain — rather than a handoff between departments — will be better positioned to absorb the next round of regulatory change without a corresponding spike in audit findings.

  • Grant Administration vs Grant Management: A Research-Office Guide

    A sponsored programmes office in a university, hospital trust, or research institute rarely has the luxury of clean job titles. Staff are asked to do “grants work” without anyone specifying which of two genuinely different functions they mean. Grant administration vs grant management is not a semantic quibble — it maps onto two distinct phases of the funding lifecycle, with different skills, different risk profiles, and different reporting lines. Getting the distinction right affects how research offices staff themselves, how they onboard new starters, and how they explain their own structure to auditors and funders.

    This explainer sets out the practical difference, shows where each function sits against the pre-award/post-award lifecycle, and answers the questions research administrators most commonly search for when trying to draw the line.

    What is grant administration?

    Grant administration is the compliance-facing, largely post-award function. It exists to make sure that once money has been awarded, it is spent, tracked, and reported exactly as the funder’s terms and conditions require. Grant administrators are the people who keep an award audit-ready from the moment funds land to the moment the final financial report is submitted.

    Typical grant administration duties include:

    • Setting up the award in the institution’s financial system and reconciling it against the signed agreement
    • Monitoring budget lines, allowable costs, and cost transfers against the approved grant budget
    • Tracking effort reporting, cost-sharing commitments, and indirect cost (overhead) recovery
    • Preparing and submitting financial and progress reports on the funder’s schedule
    • Managing award amendments, no-cost extensions, and close-out procedures

    In US institutions this work is typically anchored to the Uniform Guidance (2 CFR 200) and individual agency terms from bodies such as NIH and NSF. In the UK, the equivalent compliance backbone runs through UKRI’s grant terms and conditions, institutional TRAC (Transparent Approach to Costing) returns, and Research England reporting requirements. The regulatory vocabulary differs by jurisdiction; the underlying function — disciplined, rules-bound post-award stewardship — does not.

    What is grant management?

    Grant management is the broader, strategic function that spans the entire lifecycle: identifying funding opportunities, shaping competitive proposals, and — once an award is won — overseeing whether the funded work is actually achieving its research and institutional objectives. Where administration asks “are we compliant?”, management asks “are we winning the right grants, and are they delivering what we promised?”

    Typical grant management responsibilities include:

    • Scanning funder calls and matching them to institutional and departmental research priorities
    • Supporting principal investigators with proposal development, budget justification, and costing
    • Building and maintaining relationships with programme officers and funder liaison staff
    • Monitoring project performance against milestones, outputs, and outcomes — not just spend
    • Feeding lessons from completed awards back into future bid strategy

    A grant manager’s remit therefore extends well beyond a single award. Many sponsored programmes offices structure this as a “grants management cycle” — pre-award identification and proposal support, award negotiation, post-award delivery oversight, and closeout evaluation that feeds the next cycle.

    Pre-award vs post-award: mapping the responsibilities

    The cleanest way to separate the two functions is against the pre-award/post-award split that most research administration offices already use to structure their teams. Grant management is lifecycle-wide; grant administration is concentrated in — though not exclusively confined to — the post-award phase.

    Dimension Grant administration Grant management
    Primary lifecycle stage Post-award Pre-award through closeout
    Core question Are we compliant with the award terms? Are we funding — and delivering — the right work?
    Typical tasks Budget monitoring, cost transfers, financial reporting, audit readiness Opportunity scanning, proposal development, performance evaluation, funder relationships
    Risk focus Regulatory and financial non-compliance Strategic misalignment, missed opportunities, weak outcomes
    Reference frameworks (illustrative) Uniform Guidance (2 CFR 200), UKRI grant terms, TRAC Institutional research strategy, funder mission fit, ARMA/EARMA/NCURA practice guidance

    In practice, smaller research offices often collapse both functions into a single “research administrator” or “grants officer” role covering the full sponsored research administration remit. Larger institutions tend to separate them, with pre-award research administration and post-award research administration teams sitting either side of the award-negotiation handover point.

    Common questions on grant administration vs grant management

    What is the difference between a grant administrator and a grant manager?

    A grant administrator is primarily responsible for post-award compliance — budget monitoring, financial reporting, and adherence to funder terms. A grant manager oversees the fuller grant lifecycle, including opportunity identification, proposal strategy, and performance outcomes, though in smaller teams one person often holds both responsibilities.

    Is administration higher than management?

    Not in the grants context specifically. Generically, “administration” can refer to policy-setting and “management” to implementation, but within sponsored programmes offices the two are parallel functions — compliance-focused versus strategy-focused — rather than a strict seniority hierarchy. Either role can sit at director level depending on institutional structure.

    What is grant administration?

    Grant administration is the post-award compliance function that ensures grant funds are spent, tracked, and reported according to the funder’s contractual terms. It covers financial oversight, effort reporting, cost-transfer approval, and the preparation of interim and final reports to the awarding body.

    What is the grants management cycle?

    The grants management cycle is the recurring sequence of opportunity identification, proposal development, award negotiation, post-award delivery, monitoring, and closeout evaluation. Lessons from closeout typically feed back into the next round of opportunity identification, making it a continuous rather than linear process.

    Why the distinction matters for research offices

    Blurring grant administration and grant management has real operational costs. Institutions that treat the two as interchangeable often end up with compliance gaps — a research office focused entirely on winning new awards can miss cost-transfer deadlines or effort-reporting certifications, triggering audit findings. Conversely, an office staffed only with compliance-minded administrators can under-invest in the proposal development and funder-relationship work that keeps the award pipeline healthy.

    Professional bodies on both sides of the Atlantic reflect this split in how they organise practice guidance and training. NCURA (US) and EARMA and ARMA (UK/Europe) both maintain competency frameworks that separate pre-award and post-award skill sets, and INORMS’ Research Management and Administration career framework explicitly distinguishes strategic research management from operational research administration. This is not a CASRAI-specific taxonomy — it reflects how the wider research administration profession itself is organised, and institutions building or restructuring a sponsored programmes office should map roles against it rather than inventing local terminology from scratch.

    The distinction also matters for how institutions define career pathways. A research administration career track built purely on compliance risks losing staff who want strategic exposure; a track built purely on management risks producing officers who cannot pass an audit. The strongest sponsored programmes offices deliberately rotate staff across both functions, or pair a compliance-trained administrator with a strategy-trained manager on the same award portfolio.

    Looking ahead: convergence, not confusion

    As grant management systems increasingly automate routine compliance checks — flagging over-budget cost centres or missing certifications automatically — the administrative workload is shifting from manual reporting toward exception handling and judgement calls. That frees grant administrators to take on more of the performance-monitoring work traditionally associated with grant management, and the two functions are likely to converge further at the operational level even as they remain distinct in scope and risk ownership.

    For research offices building or auditing their own structure, the practical takeaway is not to pick one term over the other but to be explicit about which lifecycle stage — and which risk — each role is actually responsible for. That clarity, more than the job title itself, is what keeps sponsored research compliant, competitive, and well governed.

  • Grants Functional Standard: What UK Funders and Institutions Need to Know

    What Is the Grants Functional Standard (GovS 015)?

    The Grants Functional Standard — Government Functional Standard GovS 015: Grants — is the Cabinet Office document that sets mandatory expectations for how UK central government departments and their arm’s-length bodies (ALBs) design, award, monitor and close out grants. First published in December 2016 and periodically updated since, it applies to any organisation administering grants wholly or partly using Exchequer funding, which in practice includes many universities, research charities, learned societies and sector bodies that receive or pass through public grant money.

    The standard operates on a “comply or explain” basis: bodies within scope must either meet the ten Minimum Requirements or record a documented justification for departing from them. It sits alongside the wider suite of UK government functional standards (covering areas such as finance, commercial and project delivery), which exist to give civil servants and delivery partners a consistent, shared language for governance and assurance.

    The Ten Minimum Requirements

    GovS 015 is operationalised through ten numbered Minimum Requirements, each with its own supporting guidance document published by the Government Grants Management Function (GGMF). Together they cover the full grant lifecycle, from senior accountability through to reconciliation and training.

    Minimum Requirement Focus area
    1. Senior Officer Responsible for a Grant Named senior accountability for each grant scheme
    2. Governance, Approvals & Data Capture Sign-off routes and central grant-data recording
    3. Complex Grants Advice Panel (CGAP) Mandatory referral for high-risk or priority schemes
    4. Business Case Development Rationale, options appraisal and value for money
    5. Competition for Funding Fair, open, proportionate award processes
    6. Grant Agreements Terms, conditions and use of the Model Grant Agreement
    7. Risk, Controls and Assurance Fraud risk, security risk and internal controls
    8. Performance and Monitoring In-year tracking of delivery against milestones
    9. Annual Review and Reconciliation Year-end financial and delivery reconciliation
    10. Training Competency requirements for grant-making staff

    Minimum Requirement 7 — Risk, Controls and Assurance — is the section research administrators should watch most closely, because it is the one most recently amended.

    What Changed in the 21 May 2026 Update

    On 21 May 2026, the Cabinet Office published a revised version of Minimum Requirement 7: Risk, Controls and Assurance. Two substantive changes were made:

    • The language governing Fraud Risk Assessments was strengthened, tightening the expectation that grant-making bodies produce and evidence a documented fraud risk assessment as part of the standard’s risk-management requirements.
    • A new paragraph (paragraph 23) was added to provide further guidance on security risk, extending the section’s scope beyond financial and delivery risk to explicitly cover security considerations in grant-funded activity.

    This update did not change the ten-requirement structure of GovS 015 itself; it refined the assurance expectations sitting underneath Minimum Requirement 7. It follows a pattern of incremental, dated revisions the GGMF has made to individual Minimum Requirement documents over recent years — CGAP referral criteria and the Grant Agreements guidance have both been revised on a similar rolling basis. For any body already running a Grants Continuous Improvement Assessment against the standard, the May 2026 wording is the version that self-assessment evidence should now reference.

    Grant Administration, Grant Management and the Centre of Excellence

    GovS 015 sits inside a broader UK government grants ecosystem, and the terminology is often used loosely. It is worth distinguishing the parts precisely, since institutions applying the standard need to know which body owns which function.

    • Grant administration refers to the operational, transactional tasks of running a grant scheme — issuing agreements, processing claims, recording data and reconciling payments.
    • Grant management is the broader discipline: strategic design of a scheme, risk appraisal, performance oversight and continuous improvement, of which administration is one component.
    • The Government Grants Management Function (GGMF) is the cross-government function, hosted by the Cabinet Office, responsible for GovS 015 itself and for coordinating grant-making practice across departments and ALBs.
    • The Grants Centre of Excellence is the operational and advisory capability that supports departments in applying the standard consistently — providing guidance, training and shared services rather than setting the standard itself.

    What is the functional standard for grants?

    It is Government Functional Standard GovS 015, the Cabinet Office document setting mandatory requirements for how UK departments and arm’s-length bodies administer grants funded wholly or partly through the Exchequer. It exists to ensure consistency, regularity and propriety in grant-making and to promote value for money in publicly funded grant schemes.

    What are UK government functional standards?

    Functional standards are Cabinet Office-issued documents that set mandatory (“shall”) and advisory (“should”) expectations for specific government functions — finance, commercial, project delivery and grants among them. They use a shared glossary so departments and their delivery partners work to a common, auditable set of definitions and controls.

    What is the difference between grant administration and grant management?

    Grant administration is the transactional layer — agreements, claims, payments and record-keeping. Grant management is the wider strategic discipline covering scheme design, risk assessment, performance monitoring and continuous improvement, within which administration operates as one supporting activity, not a synonym for the whole function.

    What is the Grants Centre of Excellence?

    It is the cross-government advisory and capability-building resource that helps departments and arm’s-length bodies apply GovS 015 in practice, through guidance, training and shared tools. It supports implementation of the standard; it does not itself author or amend the Minimum Requirements, which remain the responsibility of the Government Grants Management Function.

    Implications for Research-Funded Institutions

    Universities, research charities and sector bodies that receive Exchequer-funded grants — directly from departments or via an ALB — sit within scope of GovS 015 even when they are not themselves a government department. The May 2026 changes to Minimum Requirement 7 have practical consequences for research administration teams:

    • Grant applications and renewals may face closer scrutiny of documented fraud risk assessments, particularly for schemes flagged as complex or high-value.
    • Institutions handling sensitive research areas — dual-use technology, critical infrastructure, or international collaboration — should expect funders to reference the new security-risk paragraph when setting due-diligence conditions.
    • Research offices that already map their processes against Minimum Requirements 1–10 for continuous-improvement self-assessment should update their MR7 evidence base to the 21 May 2026 wording.
    • Grant agreement templates and internal risk registers referencing MR7 should be checked against the current guidance rather than an earlier cached version, since the GGMF revises individual Minimum Requirement documents on a rolling basis rather than reissuing the whole standard.

    None of this changes the fundamentals of good research administration practice — due diligence, documented risk assessment and clear accountability were already core expectations. What changes is the explicitness with which fraud and security risk must now be evidenced under MR7.

    Looking Ahead

    GovS 015 has been revised incrementally rather than replaced outright since 2016, and the pattern is likely to continue: individual Minimum Requirement documents updated as risks evolve, rather than a full standard rewrite. Institutions that treat the standard as a living compliance baseline — checking dated guidance documents against their internal risk frameworks at each award cycle — will be better placed than those that rely on a static PDF saved years ago. For research administrators, the practical takeaway from the 21 May 2026 update is straightforward: fraud risk assessment and security-risk screening are no longer implicit good practice under GovS 015 — they are explicit, documented expectations under Minimum Requirement 7.

  • Research Funding Cuts in the UK: How Exposed Are Institutions to US Policy Shifts?

    British universities have spent 2026 absorbing two funding shocks at once. At home, UK Research and Innovation (UKRI) is mid-way through the biggest restructuring of its funding model since the body was created in 2017. Abroad, the US administration’s proposed reductions to federal science budgets have destabilised grant pipelines that many UK research groups quietly depend on. Research funding cuts in the UK are no longer a purely domestic story — they are increasingly a function of decisions taken in Washington, and institutions that have not mapped their transatlantic exposure are flying blind into 2027 planning cycles.

    The transatlantic funding shock: what changed in 2026

    On the UK side, the Department for Science, Innovation and Technology and UKRI confirmed in late 2025 how £38.6 billion of public R&D funding would be distributed over the following four years. The overall UKRI budget is set to rise towards £10 billion a year by 2030, but the distribution model has shifted to three “funding buckets”: curiosity-driven research, strategic government and societal priorities, and support for innovative companies — each intended to represent roughly half, a quarter and a quarter of spend respectively.

    That restructuring has not been smooth. In early 2026, three research councils — the Medical Research Council, the Biotechnology and Biological Sciences Research Council, and the Engineering and Physical Sciences Research Council — paused active grant routes. The Science and Technology Facilities Council separately confirmed it must find £162 million in cost reductions by 2029–30, driven by rising energy costs and unfavourable currency exchange rates, forcing project leaders to model cuts of 20%, 40% and even 60% to national facilities, particle physics and astronomy programmes. The House of Commons Science, Innovation and Technology Committee has since pressed UKRI’s chief executive for clearer, comparable data on the allocation changes.

    On the US side, the picture is starker still. The Association of American Universities has tracked administration proposals to cut federal research funding by 22% overall and basic research by 34% in a single fiscal year, with the Brennan Center for Justice estimating Congress was asked to strip an additional $44 billion from scientific research. The Center for American Progress estimates that National Institutes of Health (NIH) and National Science Foundation (NSF) cuts alone could cost the US economy $10–16 billion annually. Grant holds affecting Harvard and other institutions persisted well into 2026, with the NSF only lifting some holds in late May after sustained press scrutiny.

    How exposed are UK institutions to US funding shifts?

    The US is the UK’s single largest research collaborator by volume of co-authored output, and that collaboration runs through several distinct funding channels — each with a different risk profile. Institutions that treat “US exposure” as a single number miss where the real fragility sits.

    Exposure channel What is at risk 2026 signal UK mitigation lever
    Direct US federal co-funding Joint grants and sub-awards linked to NIH/NSF cycles NSF grant holds affecting Harvard and peer institutions persisted into May 2026 UKRI’s bucket reform reduces reliance on any single funding stream
    US philanthropic and foundation funding Foundation grants sensitive to the wider US fiscal and political climate US philanthropic sector under pressure to backfill federal shortfalls UK trusts, Horizon Europe association, and international co-funding
    Industry and corporate R&D partnerships Private R&D spend that tracks federal grant cycles US firms reassessing R&D allocation amid budget uncertainty UK government talent and relocation schemes attracting redirected private investment
    Talent pipeline Researchers on US-funded fellowships or joint appointments Early-career researchers facing contract non-renewal in the US UK schemes offering relocation funding for research teams

    Institutions with heavy involvement in biomedical, physics or environmental science co-funding arrangements are typically the most exposed, since these fields have historically carried the largest NIH and NSF footprints in joint UK-US work. Smaller specialist units embedded in a single US-funded programme carry proportionally more risk than large, diversified research portfolios — a distinction that should inform any institutional risk register.

    Answer-first: what researchers and administrators are asking

    Did research funding get cut?

    Yes, on both sides of the Atlantic. The UK’s Science and Technology Facilities Council confirmed £162 million in cost reductions by 2029–30, and three UKRI councils paused grant routes in early 2026. In the US, the administration proposed cutting overall federal research funding by 22% and basic research by 34% in a single fiscal year.

    Are universities getting less funding?

    Universities UK estimates that government policy decisions will reduce funding to English higher education providers by roughly £3.7 billion between 2024–25 and 2029–30. Combined with flat UKRI settlements and paused grant schemes, most English research-intensive institutions face a genuinely tighter funding environment than in the previous spending review period.

    Which UK universities are in financial trouble in 2026?

    The Office for Students has repeatedly flagged a growing minority of English providers running operating deficits, driven by falling international student income, domestic fee stagnation, and rising costs. This is a distinct pressure from research-specific council cuts, but the two compound: institutions under financial strain have less capacity to cushion research funding shocks internally.

    Why did Harvard get funding cut?

    Harvard University was among several US institutions to have NIH and NSF grants held or paused amid federal disputes over campus policy compliance. The NSF lifted some of these holds in May 2026 following media inquiries, but the episode illustrates how US federal research funding can be withdrawn on non-scientific grounds — a governance risk UK partners inherit indirectly through joint grants.

    UKRI’s own reforms as a partial buffer

    UKRI’s shift to a three-bucket funding model is contested — the Campaign for Science and Engineering has pushed UKRI for clearer year-on-year comparability, and the reform has coincided with disruptive grant pauses. But structurally, it offers UK institutions something the pre-2025 model did not: an explicit, published split between curiosity-driven research, strategic priorities, and innovation support, rather than allocation by historical research-council silos alone.

    • A published macro-level split (roughly 50% curiosity-led, 25% strategic priorities, 25% innovative companies) gives institutions a clearer basis for forecasting than opaque, council-by-council settlements.
    • UKRI has committed to providing high-level historical mapping so institutions can benchmark the new buckets against prior allocations.
    • The overall UKRI budget trajectory — rising toward £10 billion a year by 2030 — provides a growing (if unevenly distributed) domestic base that partially offsets US-side volatility, provided institutions position themselves across more than one bucket.

    None of this eliminates the pain of near-term grant pauses. But a funding architecture built around explicit strategic categories is inherently easier to diversify across than one built purely on discipline-specific council budgets — which is precisely the structural weakness that has made STFC-funded physics and astronomy groups disproportionately exposed to the current cuts.

    The case for diversification

    The practical lesson for institutional leaders is not to retreat from US collaboration — the scientific and reputational value of transatlantic partnerships remains real — but to stop treating single-source dependency as a manageable risk. UK government initiatives, including relocation-funded schemes aimed at researchers whose US positions have become uncertain, are a useful signal of where institutional and national strategy are converging, but they do not substitute for individual institutions actively rebalancing their own portfolios.

    • Map grant portfolios by funding channel (federal co-funding, philanthropic, industry, talent) rather than by discipline alone, so exposure is visible at the funding-source level, not just the subject level.
    • Treat Horizon Europe association and other multilateral schemes as genuine substitutes for at-risk US federal streams, not merely as supplementary income.
    • Build philanthropic and industry diversification into research strategy documents explicitly — the approach several research-intensive universities, including Cambridge, have already formalised.
    • Use grants management functions to track funder-level concentration risk as a standing item in institutional risk registers, not an ad hoc exercise triggered only after a funding shock.

    What this means for research administrators

    For research administration teams, the near-term task is unglamorous but essential: build an accurate, funder-level map of institutional exposure before the next funding cycle, not after it. That means treating grants management as a strategic function that sits alongside — not beneath — research strategy, with clear visibility into which grants, fellowships and facility partnerships sit on which side of the Atlantic.

    Longer term, the institutions that weather 2026’s funding turbulence best will likely be those that used UKRI’s bucket reform as an opportunity to rebalance rather than a bureaucratic inconvenience to endure. Diversification is not a hedge against any single government’s budget decisions — it is increasingly the baseline condition for research resilience.

    CASRAI’s work on the research administration function, including standards for describing contributor roles and institutional research infrastructure, sits alongside this diversification agenda — see the research administration resources, and browse funding and grants terminology in the CASRAI Dictionary.