CASRAI Dictionary

Author: MCP Service

  • Peer Review of Grant Proposals Under Political Pressure: The Case for Independence

    A funding notice should be a statement of scientific priority, not a political signal. Yet across 2025 and into 2026, the machinery that has historically separated the two — peer review grant proposals through panels of independent subject-matter experts — has come under direct pressure from proposals that would let political appointees override merit-based funding recommendations. This is an argument, not a survey: politicised screening of grant notices does not just change who gets funded, it erodes the evidentiary basis on which the public is asked to trust science at all.

    Why Independent Peer Review Underpins Public Trust

    Grant peer review exists to answer one narrow question: is this proposal, on scientific merit, worth public money? Reviewers assess feasibility, methodological rigour, and the track record of the team, insulated as far as possible from who is asking or why. UK Research and Innovation’s guidance for its research councils is explicit about this insulation: proposals go to at least three independent reviewers, comments are handled in confidence, and funders are told not to substitute journal-based metrics or reputation for direct scientific judgement, in line with the San Francisco Declaration on Research Assessment (DORA).

    That model works because it is boring by design. Merit review is meant to be the least newsworthy part of the research funding cycle — a quiet, expert, reproducible filter. When it becomes contested political territory, the filter itself becomes a variable, and every downstream claim about “the best science being funded” loses its footing.

    The 2026 Pressure Points: Political Override and Funding Cuts

    Two developments in the United States illustrate the risk. First, a proposed rule from the White House Office of Management and Budget would give political appointees at federal agencies final authority over grant funding decisions, including the ability to terminate active awards that no longer align with stated “agency priorities” or the “national interest” — language broad enough to reach almost any politically contested field, from climate science to public health. Second, budget proposals affecting the National Institutes of Health and National Science Foundation, alongside a reported NIH plan to consolidate its institutes and centres and restructure study-section peer review, have combined to shrink the pool of fundable awards even as application volume holds steady or rises.

    Neither development is hypothetical process detail. Together they change what a grant notice signals: not “this call is open to the best proposal” but “this call is open to the best proposal that also survives a discretionary political filter after review.” The Association of American Universities and multiple scientific societies have flagged this combination as a structural threat to the research enterprise, not a routine administrative reform.

    The comparison with the UK’s model is instructive, not because either system is beyond criticism, but because it shows what an evidentiary firewall between political priority-setting and technical merit assessment actually looks like in practice:

    Safeguard UKRI research council practice US 2026 OMB proposal risk
    Reviewer independence Minimum three reviewers, including one nominated by the applicant Political appointees can override expert panel recommendations
    Confidentiality Proposals handled “in confidence”; reviewer identities protected until decision No published equivalent confidentiality standard cited in the proposal
    Assessment criteria DORA-aligned; journal metrics and reputation explicitly excluded Alignment with “agency priorities” or “national interest” is an added, non-scientific criterion
    Award stability Funded projects proceed on scientific timelines set at award Active awards may be terminated mid-project if priorities shift

    Common Questions on Grant Peer Review

    What are peer-reviewed grants?

    Peer-reviewed grants are awards where an independent panel of subject-matter experts assesses a proposal’s scientific merit, feasibility, and rigour before funds are released. Agencies including NIH, UKRI, and most major foundations use this process to allocate limited public or philanthropic funding to the strongest available science, rather than by administrative discretion alone.

    What is the golden rule of peer review?

    The golden rule of peer review is to judge the work on its merits, free of conflicts of interest or external pressure. Reviewers assess methodology, evidence, and feasibility rather than the identity, politics, or institutional profile of the applicant — the same principle that underlies publication peer review under bodies such as COPE and ICMJE.

    What are the key elements of grant peer review?

    Core elements include reviewer expertise, documented conflict-of-interest management, confidentiality of unpublished ideas, structured and consistent scoring criteria, and a documented decision trail. Removing any one element — for example, by inserting a discretionary political override after panel scoring — weakens the evidentiary chain the whole process is meant to produce.

    What Politicised Review Does to the Evidence Base

    Research administrators should treat this as an evidentiary problem before it is a funding problem. If a funding decision can be overridden on non-scientific grounds after expert review, the review itself stops functioning as reliable evidence of merit — for auditors, for future meta-research, and for the public record. That has knock-on effects:

    • Grant history becomes an unreliable signal for institutional research assessment and future funder due diligence.
    • Researchers in politically sensitive fields face a de facto chilling effect, shaping what gets proposed long before any panel convenes.
    • Cross-border collaborations and co-funding arrangements, for example with Horizon Europe partners, become harder to underwrite if one partner’s award pipeline is subject to discretionary termination.
    • Standardised, interoperable research-administration infrastructure — persistent identifiers, contributor role taxonomies, funder metadata — loses value if the funding decisions it documents are not reliably merit-based.

    Forward Look: How Institutions Can Preserve Merit Review

    Research offices and institutional leaders are not bystanders here. Several concrete, defensible steps can preserve the evidentiary integrity of merit review even where political pressure on funders intensifies:

    • Document review outcomes independently. Retain institutional records of panel scores and reviewer comments separate from final award notices, so a political override is auditable rather than silent.
    • Diversify funding portfolios. Reduce single-funder dependency so that one agency’s discretionary process does not determine an entire research programme’s viability.
    • Support reviewer capacity. Volunteer reviewing is already strained by rising application volumes; institutions that credit peer-review service in promotion and workload models help sustain the expert pool the whole system depends on.
    • Use standardised, verifiable metadata. Persistent identifiers and transparent contribution records make it harder to quietly substitute political criteria for merit criteria after the fact, and easier for auditors and journalists to reconstruct what actually happened.

    None of this substitutes for the underlying policy fight over whether political appointees should hold override authority at all. But it is what research administration can control while that fight plays out — and it rests on the same logic as standardised, verifiable contribution frameworks such as CRediT, which CASRAI originated in 2014 as an interoperable way to document who did what on a piece of research; the standard is now stewarded by NISO as ANSI/NISO Z39.104-2022. Merit-based science depends on infrastructure that makes evidence, including evidence of how funding decisions were actually made, auditable rather than assumed.

  • Grant Peer Review Under OMB’s Proposed 2026 Uniform Grants Regulation

    The Office of Management and Budget (OMB) has proposed a rewrite of the federal government’s grant-making rulebook that would change how grant peer review functions across agencies including the National Institutes of Health (NIH), the National Science Foundation (NSF) and the Department of Energy. According to reporting from STAT News, Inside Higher Ed, Science and NPR, the draft rule would convert the long-standing “Uniform Guidance” (2 CFR Part 200) into a binding “Uniform Grants Regulation,” subordinating scientific merit review to a new layer of political sign-off and giving agency political appointees explicit authority to terminate awards that no longer track administration priorities.

    For research administrators, the proposal is not a routine compliance update. It touches the mechanism — independent expert review — that has underpinned federal research funding decisions for more than half a century.

    What OMB’s Proposed Grants Rule Changes

    Uniform Guidance governs financial assistance rules across virtually every federal grant-making agency, covering everything from allowable costs to audit requirements. OMB’s proposal would elevate that guidance to a binding regulation and layer several new mechanisms on top of it. The core changes reported by STAT, Inside Higher Ed, Science and NPR include:

    • A mandatory pre-issuance review of discretionary grant awards by senior political appointees before funds are released.
    • Reclassification of peer-review recommendations as advisory rather than binding or routinely deferred to.
    • An undefined “Gold Standard Science” criterion appointees may apply during sign-off.
    • Expanded termination authority for awards deemed misaligned with agency priorities, including multi-year awards already underway.
    • New pre-approval requirements for costs tied to publications, conference attendance and journal subscriptions.
    • A “domestic-first” preference framework for research and development awards.
    • Prohibitions on funding tied to diversity, equity and inclusion (DEI) activities, “gender ideology,” or research supporting disparate-impact liability theories.
    • Elimination of fixed-amount subawards.

    The public comment period is reported to close on 13 July 2026, with an anticipated effective date of 1 October 2026 if the rule is finalised largely as proposed.

    From Deference to “Advisory”: How Peer Review’s Role Shrinks

    Under current practice, agencies such as NIH route applications through scientific review groups or study sections, which score proposals on significance, approach, innovation and investigator qualifications. Program officials retain formal award authority, but in practice they defer heavily to review scores and percentile rankings to set paylines.

    The proposed rule text, as reported across multiple outlets, states that peer-review recommendations “are not ministerially ratified, routinely deferred to, or otherwise treated as de facto binding” by senior appointees. That is a structural change: a proposal that clears scientific review with a strong score could still be delayed, reprioritised or rejected at a political pre-issuance gate that sits above the merit-review process rather than alongside it.

    Research associations — including the Association of Public and Land-grant Universities (APLU), the American Association for Cancer Research (AACR) and the Computing Research Association (CRA) — have raised concerns that the change would insert non-scientific criteria into funding decisions that have historically been insulated from politics precisely to protect scientific rigour and public trust.

    Aspect Current practice Proposed rule
    Peer-review status De facto determinative for most competitive awards Explicitly advisory
    Final sign-off Program/agency officials, largely deferential to review scores Senior political appointees, mandatory pre-issuance review
    Termination grounds Non-compliance, budget, performance Adds “no longer aligned with agency priorities,” including mid-award
    Allowable costs Publications, conferences, subscriptions generally allowable Pre-approval required for these cost categories
    Subaward mechanism Fixed-amount subawards permitted Fixed-amount subawards eliminated

    Grant Peer Review: Common Questions Answered

    What is a peer-reviewed grant?

    A peer-reviewed grant is funding awarded after independent subject-matter experts assess a proposal’s scientific merit — its significance, approach, feasibility and investigator qualifications — typically through a scored study section or review panel. At NIH, review groups assign priority scores that traditionally shape funding decisions, though final award authority sits with the agency, not the reviewers.

    What is the peer review process for grant applications?

    The peer review process for grant applications routes each proposal to subject-matter reviewers, who score it against published criteria and then discuss and rank applications in a panel meeting. Agencies use these rankings to set paylines and prioritise funding. Under OMB’s proposed rule, that ranking becomes one advisory input rather than the determining factor in a funding decision.

    Do grant reviewers get paid?

    Yes. Federal agencies, including NIH, typically pay peer reviewers a daily honorarium plus travel expenses for study section service. Many reviewers describe the compensation as modest relative to the time required to read, score and discuss a full panel’s worth of competing applications ahead of each review cycle.

    Expanded Termination Authority and Award-Level Risk

    Beyond the review gate itself, the proposal reported by STAT, Science and Inside Higher Ed would broaden agencies’ authority to suspend or terminate grants — including multi-year awards already in progress — if they are deemed no longer aligned with agency priorities or the “national interest.” It would also widen risk assessment of applicants to consider an institution’s affiliation with organisations engaged in activities that “violate Federal law, undermine public safety or national security, or advocate for the overthrow of the United States Government,” a standard with considerable interpretive latitude.

    Paired with new pre-approval requirements for publication, conference and journal-subscription costs, and the removal of fixed-amount subawards, the combined effect is a research-funding environment where mid-project risk is materially higher than under the current framework, even for awards that passed scientific review cleanly.

    What This Means for Research Administrators

    For institutions managing portfolios that depend on merit-reviewed research funding, the proposal raises operational, not just scientific, questions. Recommended near-term actions include:

    • Model termination risk explicitly in multi-year budget and staffing plans, rather than treating a scored, funded award as a settled commitment.
    • Audit cost-approval workflows for publication, conference and subscription spending now, ahead of any pre-approval mandate taking effect.
    • Brief principal investigators on the distinction between a favourable peer-review score and a final funding decision under the proposed pre-issuance review.
    • Coordinate institutional comments through professional associations such as NCURA and ARMA before the docket closes.
    • Track subaward structures that rely on fixed-amount mechanisms, which the proposal would eliminate.

    Offices that have historically treated peer-review outcomes as the primary predictor of award stability will need a second, policy-alignment layer in their risk assessment — one that is harder to forecast because it depends on political judgement rather than published scoring criteria.

    What Happens Next

    The proposed rule remains open for public comment, with reporting placing the deadline at 13 July 2026 and a possible effective date of 1 October 2026 if OMB finalises it substantially as drafted. Scientific and higher-education associations are expected to submit extensive comments opposing the advisory reclassification of peer review, and legal challenges are plausible if the rule is finalised without significant revision, given its scope relative to existing statutory peer-review requirements at agencies such as NIH.

    Until the final text is published, research administrators should treat every provision summarised here as subject to change — but the direction of travel is unambiguous: less deference to scientific merit review, and more discretionary authority at the award-decision and award-termination stages. Institutions that update their risk models and compliance workflows now will be better placed to respond once the rule, in whatever form it takes, becomes binding.

  • OMB Uniform Guidance 2026 Overhaul: What Research Offices Should Flag Before the Comment Deadline

    OMB’s omb uniform guidance 2026 overhaul is now a formal proposed rule, not a rumour circulating through listservs. Published in the Federal Register on 29 May 2026 as document 2026-10817 (tracked under docket OMB-2026-0034), the proposal would rewrite 2 CFR Parts 200 and 300 — the framework governing the large majority of academic, non-profit and state federal awards — and rename it the “Uniform Grants Regulation.” The public comment window closes on 13 July 2026, days from now, with a targeted effective date of 1 October 2026, the start of federal fiscal year 2027. For sponsored-programmes offices, general counsel and research administrators, the compressed 45-day comment period means institutions that have not yet reviewed the text are already behind.

    OMB’s three stated objectives for the rewrite

    OMB has organised the proposal around three explicit objectives, set out in the preamble to the Federal Register notice:

    • Transparency, accountability and oversight — expanding federal agencies’ visibility into recipient risk, subaward reporting, conflicts of interest and termination decisions.
    • Regulatory clarity — converting 2 CFR Subtitle A from non-binding “guidance” into a document with regulatory effect in its own right, so future OMB amendments apply government-wide without separate agency rulemakings.
    • Reduced recipient burden — measures such as encouraging multi-year awards, mandating that funding opportunities post to Grants.gov, and using pre-application statements of interest to screen out low-probability applicants before a full proposal is required.

    Much of the substantive detail traces back to Executive Order 14332, “Improving Oversight of Federal Grantmaking” (7 August 2025), which directed OMB to build termination-for-convenience authority and mandatory senior-appointee review into the Uniform Guidance. The 2026 proposal is OMB’s formal vehicle for codifying that order, together with several 2025 executive orders addressing DEI, gender ideology and merit-based opportunity.

    What changes for award recipients

    The proposed rule touches nearly every phase of the award lifecycle. Recipients should not assume that practices considered compliant under the current text will automatically satisfy the revised one — several provisions are new law, not restatements.

    Section Current position Proposed change
    §200.205 – merit review Agency-run scientific/programmatic merit review Senior political appointee conducts “pre-issuance review” of every discretionary award; peer review recommendations are advisory only
    §200.340 – termination Termination chiefly for noncompliance Broad discretionary termination if an award “does not effectuate…the national interest as they exist at the time of termination”; new 90-day suspension authority
    §200.202(e) – R&D awards No domestic-entity restriction “Domestic-first framework” generally limits research and development awards to US-organised entities
    §200.220 (new) – foreign collaboration No equivalent provision Prohibits using federal funds, including indirect cost allocations, for collaboration with “covered foreign countries or entities”
    §200.461 – publication costs Generally allowable Unallowable unless required by statute or approved in advance by the agency
    §200.432 – conference costs Allowable Allowable only if expressly pre-approved in the award’s terms and conditions
    §200.333 – fixed-amount awards Permitted with agency approval Eliminated entirely, in favour of cost-reimbursement structures

    Other proposed changes worth flagging: mandatory E-Verify participation (§200.303(f)); a new requirement that recipients disclose employees who worked at the awarding agency within the prior two years (§200.112–.113); an expanded risk-assessment framework at §200.206(b) that lets agencies weigh an applicant’s Section 117 foreign-gift-disclosure compliance and “questionable practices” history; and a new subrecipient clause (§200.332(i)) obliging pass-through entities to ensure subrecipients do not “significantly damage the reputation” of the funding agency. Notably, OMB has explicitly declined to reopen indirect cost rate methodology in this rulemaking, though the pre-issuance review principle favouring “institutions with lower indirect cost rates” applies indirect downward pressure regardless.

    This is the third revision to the framework since its 2013 consolidation: OMB made administrative updates in August 2020, then a substantive 2024 revision (effective 1 October 2024) that raised the single-audit threshold from $750,000 to $1,000,000. The 2026 proposal is materially broader in scope than either predecessor, extending well beyond audit and cost mechanics into award termination, political review and non-discrimination policy — territory the Uniform Guidance has not previously occupied.

    Common questions about the 2026 Uniform Guidance rewrite

    What is the uniform guidance of 2 CFR 200?

    2 CFR Part 200, informally the Uniform Guidance, is the government-wide framework setting administrative requirements, cost principles and audit requirements for federal grants, cooperative agreements and other financial assistance. Consolidated from eight separate OMB circulars in 2013, it governs how universities, non-profits, states and tribal governments manage federal award funds.

    When did the uniform guidance change?

    OMB has revised the Uniform Guidance three times since 2013: minor administrative updates in August 2020; a substantive revision effective 1 October 2024 that raised the single-audit threshold to $1,000,000; and the sweeping rewrite proposed on 29 May 2026, targeting an effective date of 1 October 2026.

    What is the purpose of Subpart F of the Uniform Guidance in 2 CFR Part 200?

    Subpart F sets the audit requirements for non-federal entities, including the single audit obligation triggered once an organisation spends federal award funds above the statutory threshold. It defines auditee and auditor responsibilities, reporting deadlines and the criteria agencies use to assess an institution’s financial management and internal controls.

    What is the new uniform guidance threshold?

    The most recent confirmed threshold change raised the single-audit trigger from $750,000 to $1,000,000 in annual federal expenditure, effective for fiscal years ending on or after 30 September 2025. The 2026 proposed rewrite does not revisit this figure; it concentrates instead on oversight, termination authority and cost-principle changes.

    How institutions can still comment, and what happens next

    The comment window is short by design: OMB set a 45-day period specifically so that, in its words, “only a single set of government-wide requirements” applies to awards made during fiscal year 2027. Comments may be filed through Regulations.gov against docket OMB-2026-0034 or attached directly to the Federal Register listing for document 2026-10817. As of mid-June 2026 the docket had already drawn more than 14,800 public comments, reflecting the scale of institutional concern.

    Two procedural points matter for anyone drafting a submission before 13 July:

    • Grant-related rulemakings are generally exempt from the Administrative Procedure Act’s requirement that agencies individually respond to every “significant comment,” so OMB may group responses thematically in the final rule’s preamble rather than address each submitter.
    • An agency’s obligation to consider comments in judicial review is limited to the issues those comments actually raise — a specific, well-evidenced submission on a provision an institution intends to challenge later is more likely to preserve that argument than a general objection.

    Research-administration associations, including NCURA and ARMA, are coordinating member briefings and template comment language, and institutions weighing individual versus coalition submissions should consider filing both: a joint comment through a sector body carries collective weight, while an institution-specific comment on provisions with unique operational impact (large multi-year awards, extensive international collaboration, heavy publication or conference spend charged to awards) creates its own record.

    Whether or not the rule is finalised as drafted by 1 October 2026, institutions should not wait for that date to begin preparing. The executive orders underlying most of the proposed provisions — on grantmaking oversight, DEI, and foreign collaboration — are already in effect and already shaping agency behaviour in individual award decisions. Convening a cross-functional review involving the office of research, general counsel, sponsored programmes and research administration compliance staff now, before the final rule lands, is the practical way to avoid a scramble in early October. Given the volume of comments already filed and the litigation risk flagged by multiple legal analyses of the proposal, a modified final rule — rather than the text exactly as proposed — is a realistic outcome, but the direction of travel toward tighter political oversight and narrower allowable costs is unlikely to reverse.

  • The De Minimis Indirect Cost Rate: When the 15% Safe Harbor Works for Your Institution

    Every proposal budget has to answer one question: how will the institution recover the overhead it spends supporting a federally funded project? For organisations without the staff or history to negotiate a formal rate, the de minimis indirect cost rate is a standing, no-negotiation alternative built directly into the federal Uniform Guidance. It lets an eligible non-federal entity recover indirect costs on a federal award without submitting a full indirect cost rate proposal — but the rate itself, and the rules around electing it, changed materially in 2024, and many summaries in circulation still cite the old figure.

    What is the de minimis indirect cost rate?

    The de minimis rate is a fixed indirect cost recovery option set out in 2 CFR 200.414(f), the cost-principles section of the OMB Uniform Guidance that governs federal grants and cooperative agreements. It exists so that organisations without a current Negotiated Indirect Cost Rate Agreement (NICRA) are not forced to either forgo indirect cost recovery entirely or undertake a formal rate negotiation with a cognizant federal agency.

    Effective 1 October 2024, OMB revised 200.414(f) and raised the rate from a flat 10% to up to 15% of Modified Total Direct Costs (MTDC). This is the single most important recent change to the rule, and it altered its character: the rate is no longer automatically 10%, nor is it automatically 15%. The “up to” language means an electing organisation should be able to justify the rate it applies, particularly if its actual indirect costs run below 15% of MTDC.

    MTDC is a defined cost base, not simply total direct costs. It includes direct salaries and wages, applicable fringe benefits, materials, supplies, services, travel, and the first $50,000 of each subaward. It excludes equipment, capital expenditures, patient care charges, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of any subaward beyond $50,000.

    Who qualifies to elect it

    Eligibility is narrower than the phrase “de minimis” suggests. Under 2 CFR 200.414(f):

    • The entity must be a non-federal recipient or subrecipient — a state or local government, Indian tribe, institution of higher education, or non-profit organisation.
    • The entity must not currently hold a NICRA. An organisation that has never negotiated a rate, or whose prior agreement has expired without renewal, is generally the target user.
    • For-profit entities are not eligible. Cost principles for commercial organisations sit under FAR Subpart 31.2, not 2 CFR 200 Subpart E, so the de minimis election in 200.414(f) simply does not apply to them.
    • Once elected, the rate must be applied consistently across all of the entity’s federal awards until it either negotiates a NICRA or its circumstances otherwise change; it cannot be selectively applied to some awards and not others.

    In practice, the de minimis rate is used most often by first-time federal grantees, small non-profits, and institutions with genuinely modest indirect costs — organisations for whom the administrative cost of preparing a full rate proposal would exceed the financial benefit of a more precisely calculated rate.

    De minimis rate vs a negotiated rate (NICRA)

    Choosing between the de minimis rate and a negotiated agreement is a genuine trade-off, not a formality. A NICRA requires submitting a detailed indirect cost rate proposal to a cognizant federal agency, supported by an audited or auditable cost allocation base, and typically takes months to negotiate. The de minimis rate requires no proposal and no negotiation at all.

    Factor De minimis rate (up to 15% of MTDC) Negotiated rate (NICRA)
    Documentation to elect None required; self-certified election Formal indirect cost rate proposal with supporting cost data
    Time to establish Immediate Typically several months of negotiation
    Rate accuracy Fixed ceiling, may under-recover true indirect costs Reflects the institution’s actual cost structure
    Best suited to First-time or small-scale federal recipients with modest overhead Institutions with sustained federal funding and indirect costs above 15% of MTDC
    Flexibility once set Must be applied consistently to all federal awards Rate is fixed for the negotiated period, then renegotiated

    For institutions whose actual indirect costs genuinely sit at or below 15% of MTDC, the de minimis rate is a reasonable long-term choice — it avoids the recurring administrative burden of rate renegotiation. For research-intensive institutions with substantial facilities and administrative costs, a negotiated rate almost always recovers more, because negotiated F&A rates at research universities commonly run well above 15% of MTDC.

    Documentation and compliance requirements

    The de minimis election requires no formal proposal, but it is not a documentation-free zone. Institutions should still:

    • Retain a clear internal decision record showing the rate elected and the justification, especially where the rate applied is below the full 15% ceiling.
    • Apply the cost base correctly — errors in MTDC calculation, such as including full subaward amounts above $50,000 or capital equipment, are among the most common audit findings.
    • Maintain consistency: costs charged as indirect under the de minimis rate cannot also be charged directly to the same award, and vice versa.
    • Track award-level restrictions, since some individual federal programmes cap or exclude indirect cost recovery regardless of an entity’s general de minimis election.

    Common questions

    What is a de minimis indirect cost rate?

    The de minimis indirect cost rate is a standard rate that eligible non-federal entities without a current negotiated agreement may apply to recover indirect costs on federal awards. It is capped at 15% of Modified Total Direct Costs and requires no formal rate proposal to use.

    When did the de minimis indirect cost rate change?

    OMB revised 2 CFR 200.414(f) effective 1 October 2024, raising the de minimis rate from a flat 10% to up to 15% of MTDC for new federal awards. Awards issued before that date may still reference the earlier 10% figure.

    What is the current de minimis rate?

    As of the 2024 Uniform Guidance revision, the current ceiling is 15% of MTDC. Because the regulation uses “up to” language, an organisation should be able to support the specific rate it elects rather than assume 15% applies automatically.

    How do you use the de minimis rate?

    An eligible entity elects the rate by applying it directly to its Modified Total Direct Costs base on a federal award, with no application or negotiation required. Once elected, the entity must use it consistently across all federal awards until it negotiates a formal rate.

    Implications for research administrators

    The de minimis rate should not be confused with a separate and unresolved policy debate: proposed caps on negotiated indirect cost rates. In 2025, NIH and later other federal science agencies proposed capping F&A reimbursement at 15% even for institutions that already hold a NICRA well above that figure — a distinct move from the de minimis election, which has always applied only to entities without a negotiated rate. Those cap proposals drew legal challenges from higher-education associations and remain contested in federal court as of this writing. Research administrators should track the two issues separately: one is a stable, settled recovery option for smaller or first-time recipients; the other is a live policy dispute over whether research-intensive institutions’ existing negotiated rates can be unilaterally reduced.

    For institutions building or reviewing their research administration infrastructure, the practical takeaway is to treat the de minimis election as a genuine strategic choice rather than a default. Model the actual indirect cost recovery under both the de minimis ceiling and a hypothetical negotiated rate before committing, since the consistency requirement makes switching mid-portfolio administratively costly. As federal cost-recovery policy continues to shift, institutions that document their rate rationale clearly will be best placed to adapt.

  • Indirect Cost Rate Negotiation: A Step-by-Step NICRA Guide

    Every research administrator eventually confronts the same negotiation: how to persuade a federal cognizant agency that the true overhead cost of running a laboratory, a sponsored programme, or an entire research enterprise deserves fair reimbursement. The indirect cost rate that comes out of that negotiation — formalised in a Negotiated Indirect Cost Rate Agreement, or NICRA — determines how much of an institution’s administrative and facilities burden is actually recovered on every federal award it holds. This guide walks through the mechanics: how to choose a rate type, build a defensible proposal, and manage the negotiation itself.

    This is a process guide, not a policy explainer. For background on the funding-cap debate around indirect cost recovery under the OMB Uniform Guidance, see CASRAI’s separate coverage of that policy story. Here, the focus is what a research office actually has to do — and in what order — to walk out of a negotiation with a usable rate agreement.

    What Is a NICRA, and Who Needs One?

    A NICRA is a formal, signed agreement between an organisation and its cognizant federal agency — generally whichever agency provides the largest share of that organisation’s direct federal funding — that fixes the percentage rate used to recover indirect costs on federal awards. For most US colleges and universities, cognizance sits with either the Department of Health and Human Services’ Division of Cost Allocation or the Department of the Navy’s Office of Naval Research; nonprofits and other award recipients are typically assigned a cognizant agency by whichever federal funder they draw the most direct money from.

    Once negotiated, a NICRA is binding across all federal agencies, not just the one that negotiated it — a single rate agreement travels with the organisation to every subsequent federal award. Organisations that have never held a NICRA, or whose rate has lapsed, have a fallback: 2 CFR 200.414(f) permits use of a de minimis rate of up to 15% of modified total direct costs (MTDC) without negotiation, though that rate must then be applied consistently across every federal award until a negotiated rate is obtained.

    Preparing the Indirect Cost Rate Proposal

    Before submitting anything, the research office has two decisions to make: which rate type to request, and what documentation the proposal will need to withstand review.

    Rate type Definition Adjustable later?
    Provisional Temporary rate used for interim billing pending a final rate for the same period Yes — reconciled against actual costs
    Final Rate set once actual costs for a completed fiscal year are known No
    Predetermined Fixed rate set in advance for a future period, based on a prior representative period’s actual costs No, for that period
    Fixed with carry-forward Predetermined rate with a built-in adjustment for the gap between estimated and actual costs Adjusted in the following period

    Organisations that have never negotiated a rate should generally submit their first proposal within three months of receiving a federal award; organisations with an existing NICRA must submit an updated proposal within six months of the close of each fiscal year covered by that agreement. Missing this window can force an organisation back onto the de minimis rate until a new proposal is accepted.

    A complete indirect cost rate proposal package typically includes:

    • A cover letter stating the fiscal period, rate type requested, and allocation base
    • An organisational chart and description of each unit’s functions
    • Audited financial statements or a Single Audit Report for the fiscal year under review
    • A cost policy statement setting out which costs are charged directly versus indirectly
    • The indirect cost rate calculation itself — indirect cost pool divided by the chosen direct cost base — reconciled line-by-line to the financial statements
    • A schedule of salary and wage allocation between direct and indirect functions
    • A statement of employee fringe benefits
    • A complete listing of federal grants and contracts active during the fiscal year
    • A signed Certificate of Indirect Costs and lobbying certification

    Every unallowable cost — entertainment, alcohol, lobbying, fundraising — must be scrubbed from the indirect cost pool before submission; a proposal that includes unallowable costs, even inadvertently, is the single most common reason negotiations stall.

    Negotiating With Your Cognizant Agency

    Once a proposal is accepted for review, a negotiator or auditor at the cognizant agency is assigned to check compliance with the applicable federal cost principles — 2 CFR Part 200 (the Uniform Guidance) for nonprofits, colleges, and local governments, or FAR Part 31 for commercial organisations under agencies such as the Defense Contract Audit Agency. Expect an iterative back-and-forth: requests for supporting documentation, clarification of allocation methodologies, and questions about specific cost pool line items.

    If agreement is reached, the cognizant agency issues the NICRA for signature. If it is not — because of disputed pool expenses or a disagreement over the allocation base — the agency may instead issue a unilateral rate agreement. An organisation that disagrees with a unilateral rate typically has a defined window (30 days, under NSF’s published appeal procedures) to invoke formal appeal procedures before the unilateral rate takes effect by default.

    What is the difference between direct and indirect costs?

    Direct costs are expenses specifically identifiable with a single project — a piece of equipment, a research assistant’s salary. Indirect costs, sometimes called facilities and administrative (F&A) costs, are shared expenses — utilities, general administration, facilities maintenance — that benefit multiple projects and cannot be assigned to just one.

    How do you calculate an indirect cost rate?

    An indirect cost rate is calculated by dividing the total indirect cost pool by a chosen direct cost base, typically modified total direct costs (MTDC). The resulting percentage is applied to that base on each award to determine how much indirect cost recovery the project generates.

    What percentage should indirect costs be?

    There is no single “correct” indirect cost rate — negotiated rates vary widely by institution type, facilities intensity, and cost base. Organisations without a negotiated rate may instead use the de minimis rate of up to 15% of modified total direct costs under 2 CFR 200.414(f).

    What is an example of an indirect cost?

    Common examples include administrative salaries, building depreciation, utilities, general liability insurance, and shared IT infrastructure — costs that support the whole organisation rather than any single sponsored project.

    Implications for Research Offices and What Comes Next

    Negotiating a NICRA is resource-intensive: it typically demands sustained input from finance, sponsored programmes, and facilities staff over several months, and the resulting rate directly shapes how much overhead recovery an institution can budget against every subsequent federal award. Institutions weighing whether negotiation is worth the administrative overhead should treat the de minimis 15% MTDC rate as a genuine fallback for smaller or first-time federal recipients, not a permanent compromise — most organisations with significant sustained federal funding recover meaningfully more through a negotiated rate over time.

    Because a signed NICRA binds every federal agency, not just the one that negotiated it, getting the proposal right the first time avoids repeat renegotiation cycles. As indirect cost recovery policy continues to attract political scrutiny at the federal level, research offices that maintain clean, well-documented cost pools and submit proposals on schedule will be best placed to defend their negotiated rates regardless of how the broader policy debate resolves. Robust research administration practice — accurate cost allocation, disciplined recordkeeping, and early engagement with the cognizant agency — remains the most reliable lever an institution controls in this process.

  • Certified Research Administrator (CRA): What the 2026 Exam Actually Tests

    The Certified Research Administrator (CRA) credential is having a quiet moment in 2026, as the Research Administrators Certification Council (RACC) runs its first full cycle under a revised three-year recertification term and a scaled-scoring exam format introduced in fall 2023. For institutions deciding whether to fund staff toward certification, the practical questions are rarely about prestige — they are about eligibility routes, sitting windows, cost, and exactly what the exam’s “Body of Knowledge” covers. This piece works through RACC’s own published materials to answer them.

    What the CRA Credential Signals

    RACC was founded in 1993 as an independent, private non-profit organisation, and it remains the sole body that awards the CRA designation in the United States. The credential is a registered certification mark with the US Patent and Trademark Office, and it sits alongside two sibling credentials RACC also administers: the Certified Pre-Award Research Administrator (CPRA) and the Certified Financial Research Administrator (CFRA).

    As of RACC’s own directory count reported in 2022, roughly 3,296 active CRAs were listed on the council’s public register. The credential is not a degree or a job title; it is a portable signal that a research administrator has met minimum eligibility criteria and passed a standardised, psychometrically developed examination covering sponsored-programme administration.

    Eligibility and How to Apply for the 2026 Cycle

    RACC sets three alternative eligibility routes for the CRA, CPRA, and CFRA exams, distinguishing between formal education and years of direct professional experience in research or sponsored-programme administration:

    • A bachelor’s degree (or higher) plus three years of professional research administration experience.
    • An associate degree plus five years of professional research administration experience.
    • No degree plus six years of professional research administration experience, subject to a waiver petition approved by RACC.

    Candidates apply online through RACC’s testing partner, the Professional Testing Corporation (PTC), and pay a $395 USD examination fee — credit card only; mailed paper cheques are not accepted. Every applicant is expected to read the current CRA candidate handbook in full before applying, since it sets out domain weighting, permitted materials, and testing-centre logistics that PTC and Prometric enforce on exam day.

    Inside the Body of Knowledge: What the Exam Actually Tests

    RACC organises its CRA content outline into four broad domains, collectively referred to as the Body of Knowledge:

    • Project Development and Administration
    • Legal Requirements and Sponsor Interface
    • Financial Management
    • General Management

    Since fall 2023, every CRA exam has comprised 200 multiple-choice questions delivered over three-and-a-half hours: 175 scored items plus 25 unscored pretest (pilot) questions seeded randomly throughout the paper, so no candidate can identify which items do not count. RACC also moved to scaled scoring at that point, reporting results on a 200–800 scale with a fixed passing point of 500 — a statistical equating process keeps the passing standard consistent across different exam forms.

    Item development follows a three-stage process: an Item Writing Committee of active certificants drafts multiple-choice questions against the Body of Knowledge outline; an Item Review Committee checks accuracy, distractor quality, and domain coding; and an Exam Review Committee assembles the final form, checking for duplication and confirming that referenced regulations and agencies are current, before PTC transfers the exam to Prometric for delivery.

    What is a CRA administrator?

    A CRA administrator is a professional who holds the Certified Research Administrator credential, verifying competence across RACC’s four Body of Knowledge domains — project development, legal and sponsor requirements, financial management, and general management. The designation signals readiness to administer federally funded grants and contracts at a research institution.

    How long is the CRA exam?

    Candidates are given three-and-a-half hours to complete the CRA exam. As of fall 2023, the paper contains 200 multiple-choice questions, of which 175 count toward the candidate’s scaled score and 25 are unscored pretest items distributed randomly, so no test-taker can identify which questions are being piloted for future forms.

    What does “CRA certified” mean?

    “CRA certified” means an individual has satisfied RACC’s degree-and-experience eligibility criteria and passed the Certified Research Administrator examination — a credential registered as a certification mark with the US Patent and Trademark Office. It signals verified competence in sponsored-programme administration, not an academic degree or an employer-assigned job title.

    How do you become a certified research administrator?

    To become a certified research administrator, a candidate must meet one of RACC’s three eligibility routes, apply online through the Professional Testing Corporation portal, pay the $395 fee, and pass the 200-question Body of Knowledge exam during one of RACC’s official testing windows within the given cycle.

    2026 Testing Windows, Recertification, and What It Means

    RACC publishes fixed testing windows and application deadlines for each of its three credentials rather than year-round, on-demand testing. The 2026 schedule is as follows:

    Credential 2026 testing window Application deadline
    CRA 9–23 May 2026 8 April 2026
    CRA 7–21 November 2026 1 October 2026
    CPRA 14–28 February 2026 14 January 2026
    CPRA 15–29 August 2026 15 July 2026
    CFRA 7–21 March 2026 4 February 2026
    CFRA 12–26 September 2026 12 August 2026

    Recertification is where RACC’s own rules have changed most for existing holders. Every certification previously ran on a five-year cycle requiring 80 contact hours; RACC has since moved to a three-year cycle requiring 42 contact hours, with a transition rule that lets anyone certified before 2023 complete one more five-year cycle before the new three-year term applies. The recertification application fee is $195 (or $295 if filed late), and RACC audits a portion of submitted contact-hour transcripts rather than verifying every application up front.

    Recertification term Contact hours required Standard / late fee
    Legacy 5-year term 80 hours $195 / $295
    Current 3-year term 42 hours $195 / $295

    For institutions weighing whether to sponsor staff through certification, the shift to a shorter, lower-hour recertification cycle lowers the long-run maintenance burden per candidate, even though it compresses the interval between renewals. Combined with a fixed, published Body of Knowledge and transparent testing windows, the CRA sits as one of relatively few standardised, third-party-audited credentials available to the wider research administration profession — a profession where most other professional development remains institution-specific or association-run rather than independently examined.

    Administrators considering the 2026 cycle should treat the candidate handbook, not marketing copy, as the primary source: eligibility routes, fee schedules, and testing windows are all subject to periodic revision, and RACC has shown in the fall-2023 scoring changes and the move to three-year recertification that it will update its own rules with limited notice.

  • Certified Pre-Award Research Administrator (CPRA) vs CRA vs CFRA: Choosing Your Career Pathway

    RACC’s next virtual sitting for the certified pre-award research administrator CPRA examination is scheduled for 16–17 July 2026, with the financial-track CFRA sitting following on 13–14 August. For research administrators weighing which of the Research Administrators Certification Council’s three credentials to pursue, the choice is rarely about exam difficulty — the eligibility bar is identical across all three. It is about which slice of the sponsored-programs lifecycle matches your actual day-to-day role.

    This guide maps the Certified Research Administrator (CRA), Certified Pre-Award Research Administrator (CPRA), and Certified Financial Research Administrator (CFRA) credentials to career stage and institutional function, rather than repeating exam-registration mechanics already covered by RACC’s own candidate handbooks.

    What RACC’s Three Credentials Actually Cover

    The Research Administrators Certification Council was founded in 1993 as a private non-profit body headquartered in Westminster, Colorado. It designs and governs three distinct credentials, each built on its own Body of Knowledge and administered through Professional Testing Corporation (PTC), with exams delivered at Prometric testing centres.

    The CRA is the original, generalist credential. Its Body of Knowledge spans four domains: project development and administration, legal requirements and sponsor interface, financial management, and general management. It suits administrators whose remit already crosses the full award lifecycle. CPRA and CFRA split that same territory into two specialist lanes — pre-award and post-award financial — for administrators whose roles are narrower but deeper.

    Credential Primary scope Typical role focus Validity period
    CRA Full sponsored-programs lifecycle (generalist) Directors, senior generalists overseeing pre- and post-award functions 3 years, then recertification
    CPRA Pre-award: proposal development, sponsor interface, budgeting, compliance before an award is made Grants officers, proposal development specialists, pre-award coordinators 3 years, then recertification
    CFRA Post-award financial management: award set-up, cost allowability, effort reporting, closeout Grant/financial administrators, sponsored-programs accountants 3 years, then recertification

    A detail that competitor exam-prep pages routinely gloss over: RACC’s eligibility requirements are identical for all three exams. Whether you sit the CRA, CPRA, or CFRA, you need a bachelor’s degree (or higher) plus three years of research-administration experience, an associate degree plus five years, or six years of experience with no degree (subject to a waiver petition). The credentials differ in subject-matter scope, not in seniority or difficulty threshold — a distinction that matters when institutions build certification into promotion criteria.

    Mapping Each Credential to Career Stage and Institutional Role

    Because eligibility is uniform, the deciding factor should be job function rather than years of service. In practice, the three credentials map onto distinct points in a typical research administration career pathway:

    • Pre-award specialists and grants/proposal officers — administrators whose work ends when an award is signed (proposal development, sponsor policy interpretation, budget construction, submission compliance) are best matched to the CPRA.
    • Post-award financial administrators and sponsored-programs accountants — those managing award set-up, subrecipient monitoring, effort reporting, cost transfers, and closeout should target the CFRA.
    • Directors, associate directors, and generalist research administrators — professionals whose role already spans both pre- and post-award functions, or who are moving toward institutional leadership, are the natural audience for the broader CRA.
    • Early-career staff still rotating through functions — many institutions encourage new hires to accumulate the minimum three years of experience before sitting any RACC exam, then choose CPRA or CFRA based on which function they land in permanently.

    A common pattern among senior administrators is credential stacking: earning the CPRA or CFRA first, aligned to an initial specialist role, then adding the CRA once a promotion broadens the job description to cover the full lifecycle. RACC’s three-year revalidation cycle makes this staged approach practical rather than duplicative.

    Answer-First: Common Questions About RACC Certification

    What is a CPRA certification?

    A CPRA (Certified Pre-Award Research Administrator) is a credential from the Research Administrators Certification Council confirming that an individual has met RACC’s eligibility requirements and passed an exam covering pre-award functions — proposal development, sponsor interface, budgeting, and compliance — before an award is made.

    How do you become a certified research administrator?

    Candidates must first meet one of RACC’s three eligibility tiers — a bachelor’s degree plus three years of research-administration experience, an associate degree plus five years, or six years with no degree — then pass the relevant CRA, CPRA, or CFRA exam, delivered through Prometric testing centres on RACC’s published exam schedule.

    How much does the certified research administrator exam cost?

    Published RACC candidate handbooks have listed an exam application fee in the region of $395 for the CRA exam, payable when submitting a candidate application to Professional Testing Corporation. CPRA and CFRA follow a comparable fee structure; current amounts are confirmed on RACC’s exam-schedule page each cycle.

    What does a certified research administrator do?

    A certified research administrator oversees sponsored-programs work spanning proposal development, sponsor interface, financial management, and general management across universities, hospitals, and research institutes. The CRA’s broad scope contrasts with the narrower pre-award (CPRA) and financial (CFRA) specialisations RACC also certifies.

    What Certification Signals to Institutions and Funders

    For hiring managers reviewing a grant administrator job description, a RACC credential is an external, third-party-verified signal that a candidate has already demonstrated competence against a defined Body of Knowledge, rather than relying solely on a CV’s self-reported experience. That matters most in two contexts: multi-institution consortium grants, where sponsors and partner institutions have no direct visibility into staff training; and internal promotion panels, where an objective, recertifiable credential provides a defensible criterion alongside tenure and performance review.

    Certification is not, however, a proxy for local regulatory knowledge. RACC’s Body of Knowledge is built around U.S. federal sponsor rules and U.S. institutional norms. Institutions outside the United States — including those following UKRI or Horizon Europe funding terms — should treat CRA/CPRA/CFRA as evidence of general professional competence and structured domain knowledge, not as a substitute for jurisdiction-specific compliance training.

    On compensation, published certified research administrator salary data is best sourced from ARMA International and NCURA member salary surveys rather than generic job-board estimates, since research-administration titles and pay bands vary widely by institution type, region, and whether the role sits in a central office or a departmental unit.

    Choosing Your Pathway

    The RACC credential set was not designed to rank administrators by seniority — it was designed to certify distinct bodies of knowledge that happen to map cleanly onto how sponsored-programs offices actually divide labour. Treating CPRA as a “junior” credential and CRA as a “senior” one misreads a system where eligibility is constant and scope is the only variable.

    As research-administration teams continue to specialise — particularly in larger offices splitting pre-award and post-award functions into separate teams — expect CPRA and CFRA uptake to keep pace with, or outstrip, the generalist CRA among staff below director level, while CRA remains the marker most associated with cross-functional leadership roles. Administrators planning a multi-year research administration career pathway should map their target credential to the function they intend to own next, not the one that simply sounds most senior.

  • DORA at the Crossroads: What a Three-Year Reform Plan Achieved (and What Comes Next)

    The San Francisco Declaration on Research Assessment (DORA) is closing out a three-year strategic plan that has shaped how universities, funders and publishers approach dora research assessment since 2023. As the cycle concludes in 2026, institutional leaders — many already drafting roadmaps for the UK’s REF 2029 cycle — are asking a pointed question: did the plan change how research is actually evaluated, or did it mostly formalise commitments that were never operationalised?

    The stakes are not abstract. Hiring, promotion and tenure committees, grant panels and REF sub-panels all rely on criteria that DORA has argued for over a decade are distorted by proxy metrics such as the journal impact factor. As the strategic plan closes, the answer matters for every research office deciding whether reform commitments become working policy or remain a signature on a webpage.

    This article takes stock of what the 2023-2026 plan aimed to achieve, where UK institutions stand relative to global peers, and what research administrators should prioritise as DORA and adjacent initiatives such as the Coalition for Advancing Research Assessment (CoARA) move into their next phase.

    What Is DORA Research Assessment, and Why Did It Need a Strategic Plan?

    For research offices still asking what DORA research assessment means in practice, the answer starts with a single recommendation: stop using journal-level metrics — above all the journal impact factor — as a proxy for the quality of an individual researcher’s work or an individual article. DORA originated in 2012 and has since grown from a single declaration into a sector-wide movement spanning universities, funders, publishers and learned societies. Its recommendations ask institutions to judge research on its own merits, considering the full range of scholarly outputs — datasets, software, preprints and contributions that fall outside traditional authorship — rather than defaulting to where a paper was published.

    Signing the declaration was always the easy part. Translating a set of general recommendations into workable hiring, promotion and tenure (HPT) criteria, grant assessment rubrics and departmental review processes is a slow, resource-intensive institutional change project — precisely the gap the 2023-2026 strategic plan was designed to close. Rather than continuing to prioritise signatory growth alone, the plan shifted DORA’s emphasis toward implementation support: practical HPT guidance, regional and language-specific outreach, and case studies intended to help signatories move from a values statement to an operating policy.

    Three Years of Reform: What the Plan Set Out to Do

    Across the plan period, DORA’s public-facing work concentrated on a small number of practical levers rather than advocacy alone:

    • Implementation tools over pledges. Resources such as hiring, promotion and tenure guidance were positioned as the primary deliverable for signatories, shifting the conversation from “have you signed?” to “what has changed in your criteria documents?”
    • Recognition of institutional reformers. DORA has used award and case-study mechanisms to surface institutions that rewrote review criteria, giving other research offices templates to adapt rather than starting from a blank page.
    • Alignment with parallel coalitions. DORA’s messaging increasingly converged with CoARA, the European-led coalition committing signatories to move away from inappropriate use of journal- and publisher-based metrics in research assessment, reducing duplicated effort for institutions that had signed both.
    • Sector-specific outreach. Funders, publishers and academic societies were treated as distinct audiences, reflecting the reality that a funder’s assessment reform (grant panel criteria) looks nothing like a university’s (promotion criteria).

    The honest assessment, three years on, is uneven progress. Awareness of responsible research assessment as a concept is now mainstream in research administration circles — it features regularly at EARMA, ARMA, NCURA and INORMS conferences and working groups. But the distance between a signed declaration and a rewritten promotion criteria document remains, in most institutions, unclosed. Many committees still ask candidates for journal names and citation counts in practice, even where formal policy documents have been updated to discourage it.

    The UK Picture: DORA Signatories and the REF 2029 Shadow

    The UK has one of the highest concentrations of DORA signatories in the world, a legacy of the sector-wide reckoning triggered by the Metric Tide report and reinforced by the REF 2021 panel criteria, which explicitly discouraged the use of journal impact factors and similar metrics in the assessment of research outputs. Major funders — including UKRI — sit among UK DORA signatories, alongside a large number of universities and learned societies, which gives the UK an unusually joined-up signatory base compared with many peer countries.

    That density creates both an advantage and a risk as REF 2029 preparations get underway. The advantage is that UK institutions do not need to relitigate the case for reform — funders and REF panels have already stated the principle. The risk is complacency: because so many UK organisations already appear on the DORA signatories UK list, there is a temptation to treat the declaration as a compliance checkbox rather than a live obligation to keep auditing hiring, promotion and tenure practices as REF 2029 criteria are finalised. Institutions that treated their DORA signature as a one-off communications exercise in 2013 or 2018 are now the ones scrambling to demonstrate genuine reform as REF 2029 assessment frameworks take shape.

    Where Responsible Research Assessment Still Falls Short

    Two pressures are complicating the responsible research assessment agenda as DORA’s plan concludes. First, generative AI is reshaping both research production and research misconduct risk — organisations including COPE and Retraction Watch have documented a growing caseload of AI-related integrity concerns, from fabricated citations to undisclosed AI-generated text, which assessment reform efforts were not originally designed to address. Second, the metrics DORA sought to displace have not disappeared; they have migrated into AI-generated research summaries, university rankings and funder dashboards that quietly reintroduce citation-based proxies under new interfaces.

    There is also a persistent recognition gap: contribution to a paper is still frequently reduced to authorship order, even though structured contribution taxonomies exist to describe roles more precisely. CASRAI originated the CRediT contributor role taxonomy in 2014; the standard is now stewarded by NISO as ANSI/NISO Z39.104-2022. Wider adoption of structured contribution statements — alongside persistent identifiers such as ORCID iDs and ROR organisation identifiers, and metadata standards maintained by DataCite and CrossRef — gives assessment committees a genuine alternative to inferring contribution from author-list position. DORA’s own recommendations point in this direction, but uptake in HPT panels remains inconsistent.

    What This Means for Research Administrators

    For institutional leaders assessing their own reform roadmaps as DORA’s plan concludes, three actions stand out:

    • Audit, don’t assume. Confirm whether HPT criteria documents have actually been rewritten since your institution signed DORA — a signature date is not evidence of implementation.
    • Build REF 2029 criteria around structured contribution data. Require ORCID iDs, ROR affiliations and CRediT-style contribution statements in internal reporting systems now, so REF 2029 narrative CVs and case studies are drafted from clean data rather than reconstructed after the fact.
    • Treat CoALition-adjacent commitments as one workstream, not several. Institutions signed up to DORA, CoARA, and cOAlition S-aligned open access policies should map these into a single responsible-assessment policy rather than managing three parallel compliance exercises with overlapping asks.

    Conclusion: A Plan Ends, the Work Continues

    DORA’s 2023-2026 strategic plan will close having shifted the sector’s vocabulary — responsible research assessment is now a standard term in research administration — without yet closing the gap between policy and practice at most signatory institutions. The organisations best positioned for whatever DORA and CoARA announce next are those that used this plan cycle to rewrite HPT criteria and adopt structured contribution and identifier data, rather than those that simply renewed their signatory status. As REF 2029 preparations intensify across the UK, that distinction will separate institutions that can demonstrate reform from those that can only cite a declaration.

  • Horizon Europe’s Open Access Mandate for Monographs and Books: What Publishers Need to Know in 2026

    Publishers of academic monographs and edited volumes have a narrowing compliance window in 2026. Institutional guidance issued by research offices across the European Research Area has now confirmed what many university presses suspected was coming: the Horizon Europe monograph open access requirement is being applied as an immediate, no-embargo obligation, not the softer “within twelve months” allowance that long-form outputs enjoyed under Horizon 2020. For scholarly and university-press publishers still relying on embargo windows to protect print sales, the operational implications are significant.

    The shift matters because monographs and edited volumes occupy a different economic and editorial position from journal articles. Peer review cycles are longer, production costs are higher, and many presses depend on frontlist sales in the first year after publication to recoup costs. A mandate that removes the embargo option for Horizon Europe-funded books effectively forces a shift toward open-access business models — book processing charges, subvention funds, or collective funding mechanisms — well before most presses had budgeted for it.

    The Horizon Europe Monograph Open Access Mandate: What Changed

    Horizon Europe’s Model Grant Agreement has, since the programme’s launch, required beneficiaries to ensure open access to peer-reviewed scientific publications arising from funded research, with deposit in a trusted repository at the latest at the time of publication. For journal articles this has meant immediate open access with no embargo permitted — a marked tightening compared with Horizon 2020. Monographs, book chapters and other long-form outputs, however, historically sat in a grey zone: guidance permitted longer embargoes given the different production and revenue model of long-form scholarly publishing.

    Institutional research offices are now reporting that this grey zone has closed. Updated guidance interpreting the Annotated Grant Agreement treats monographs and edited volumes arising from Horizon Europe grants as subject to the same immediate open access expectation as articles, with limited scope for embargo exceptions and only where a beneficiary can demonstrate a documented conflict with legitimate commercial interests, such as a pre-existing publishing contract negotiated before the mandate took effect. In practice, this means grant-holders negotiating new book contracts from 2026 onward should assume zero embargo is the default position, not the exception.

    CC Licensing Rules for Long-Form Outputs

    The licensing dimension is equally consequential. Horizon Europe’s default licensing requirement is CC BY (or a licence with equivalent rights) for the version of record or the final peer-reviewed manuscript, with CC BY-ND permitted in specific cases where the beneficiary can justify it — for instance, to protect the integrity of a monograph’s narrative argument or illustrative content from unauthorised adaptation. For edited volumes with multiple contributing authors, this creates a coordination burden that journal publishers rarely face: every contributor’s chapter must carry a licence consistent with the funder mandate, and permissions for third-party material (images, maps, quoted text) must be cleared for reuse under an open licence rather than the more restrictive “all rights reserved” terms many presses still default to in contracts.

    Publishers should also note that Horizon Europe’s guidance treats the CC licensing requirement as attaching to the funded output itself, not to the press’s broader catalogue. This means a single edited volume may need to carry different licensing terms for different chapters if only some contributors were funded by Horizon Europe grants — a scenario production and rights teams need workflow support to manage rather than resolving case-by-case at proof stage.

    Which Horizon Europe Calls Are Affected

    The monograph mandate is not confined to a single funding stream. It applies wherever a Horizon Europe grant supports the underlying research, which means publishers should expect it across the full spread of Horizon Europe calls that fund book-length outputs — most visibly in Cluster 2 (Culture, Creativity and Inclusive Society), where monographs remain a primary dissemination format, but increasingly in interdisciplinary projects funded through Horizon Europe cluster 5 calls (Climate, Energy and Mobility) where policy-facing edited volumes and technical assessment books are common outputs. The Horizon Europe work programme 2025 carried forward the same open access conditions into 2026-funded actions, so presses handling manuscripts from projects awarded under that programme are already inside the compliance window.

    Health-focused publishers should pay particular attention. Horizon Europe health calls 2026 continue to fund large collaborative projects that frequently produce edited clinical or public-health volumes alongside journal outputs, and the European Commission’s open science requirements apply equally to both formats. University presses that have historically treated health-adjacent edited volumes as a niche, lower-volume category may find that Horizon Europe-funded health projects now represent a disproportionate share of their open-access compliance workload, simply because health clusters fund so many large consortia.

    Attribution and Contributor Roles in Edited Volumes

    Open access mandates for long-form outputs also intersect with a separate but related trend: growing demand for standardised, machine-readable contributor attribution in multi-author books. Journal publishers have widely adopted the CRediT contributor role taxonomy to disambiguate who did what across large author lists; edited volumes with dozens of chapter authors face an analogous — arguably more acute — attribution challenge. CASRAI originated the CRediT contributor role taxonomy in 2014. The standard is now stewarded by NISO as ANSI/NISO Z39.104-2022. Presses building open-access metadata workflows for Horizon Europe-funded volumes should consider whether chapter-level contributor statements, alongside ORCID identifiers for editors and authors, would strengthen compliance reporting to funders and simplify downstream indexing by DataCite and CrossRef.

    What This Means for Research Administrators

    For research offices and grant administrators, the practical consequences fall into four areas:

    • Contract review: existing book contracts negotiated before a project’s Horizon Europe award should be audited for embargo and licensing clauses that now conflict with grant conditions.
    • Budgeting for book processing charges: administrators should confirm with principal investigators whether monograph publication costs have been included in the project budget, since immediate CC BY publication is rarely free.
    • Repository deposit workflows: institutional repositories need to support long-form deposit (full manuscripts, not just abstracts) at the point of publication, which is a different technical and rights-clearance workload than article deposit.
    • Coordination with university presses: where the institution operates its own press, research offices should establish a standing liaison so that acquisitions editors flag Horizon Europe-funded projects at contract stage, not at the point of camera-ready delivery.

    Organisations such as EARMA and ARMA have both flagged long-form open access compliance as an emerging gap in research administration training, and institutions preparing for the next REF cycle in the UK should note that funder-mandated open access terms for books can diverge from REF open access requirements, creating dual-compliance obligations that need to be reconciled rather than assumed to be identical.

    Looking Ahead

    The direction of travel is unambiguous: funders are converging on the position that “open access” means immediate, machine-readable, openly licensed access regardless of output format, and the historical carve-out for monographs is narrowing across the research funding landscape, not only within Horizon Europe. Publishers that build book-processing-charge models, chapter-level rights workflows and CC BY-compliant production pipelines now will be better positioned as other funders — building on cOAlition S’s long-standing work on open access books — follow the same trajectory. For scholarly and university-press publishers, 2026 is the year monograph open access stops being a policy aspiration and becomes a contractual condition of funding.

  • Narrative CVs Explained: A Practical Template Guide for Funders and Institutions

    Research administrators preparing institutional guidance ahead of the REF 2029 cycle are increasingly asking the same question: what does a good narrative CV academia example actually look like, and how do we build a template our researchers will actually use? The shift away from publication counts and journal impact factors toward structured, narrative-style CVs — pioneered by UKRI’s Résumé for Research and Innovation and echoed in funder policies across Europe — is no longer experimental. It is fast becoming the default expectation for grant applications, promotion cases, and fellowship reviews.

    The pressure is coming from several directions at once. The Declaration on Research Assessment (DORA) has spent a decade arguing that journal-level metrics are poor proxies for the quality of individual contributions. The Coalition for Advancing Research Assessment (CoARA) — whose CoARA agreement now counts hundreds of signatory universities, funders, and national agencies — commits members to reforming assessment criteria to reward openness, collaboration, and societal contribution alongside traditional outputs. UKRI’s own narrative CV format, built around the Résumé for Research and Innovation, has been mandatory for many grant schemes since 2021 and continues to expand into new panels as the REF 2029 cycle takes shape.

    For institutions still relying on traditional CV templates, this creates a practical gap: researchers need concrete examples and adaptable structures, not just policy statements. This piece sets out what a workable narrative CV template looks like in practice, how it aligns with responsible metrics principles, and what research administrators should build now.

    A Narrative CV Academia Example: Inside the UKRI Résumé for Research and Innovation

    UKRI’s Résumé for Research and Innovation format organises a career narrative around four headings rather than a chronological list of outputs:

    • Contributions to the generation of knowledge — research outputs, but framed around significance and contribution rather than volume or venue.
    • Contributions to the development of individuals — mentoring, supervision, training delivery, and team leadership.
    • Contributions to the wider research community — peer review, editorial roles, committee service, and infrastructure work.
    • Contributions to broader society — public engagement, policy influence, and translation of research into practice.

    Applicants are asked to select a limited number of contributions under each heading and describe, in plain narrative prose, what they did, why it mattered, and what role they played — particularly important for collaborative or multi-author work where a simple author list obscures individual contribution. This is precisely where the CRediT contributor role taxonomy becomes useful as a supporting tool. CASRAI originated the CRediT contributor role taxonomy in 2014, and the standard is now stewarded by NISO as ANSI/NISO Z39.104-2022; the fourteen defined roles (conceptualisation, methodology, investigation, funding acquisition, and so on) give applicants a controlled vocabulary for describing exactly what they contributed to a joint output, rather than relying on author position or vague phrasing such as “significant contribution.”

    Other funders and institutions have adapted similar structures. The Swiss National Science Foundation, the Dutch Research Council (NWO), and several UK universities’ promotion frameworks now use comparable narrative sections, typically capped at two to four pages, with explicit prompts to avoid journal names, impact factors, or citation counts as stand-alone evidence of quality.

    Why Narrative Formats Align with DORA, CoARA, and the Leiden Manifesto

    Narrative CVs did not emerge in isolation. They are the practical expression of three overlapping reform movements that research administrators should understand as a connected policy landscape rather than separate initiatives:

    • DORA asks institutions to stop using journal impact factor as a proxy for the quality of individual research articles, and to evaluate scientific content on its own merits.
    • The Leiden Manifesto for research metrics sets out ten principles for the responsible use of research metrics, including that quantitative evaluation should support, not replace, qualitative expert assessment, and that metrics should be transparent and verifiable to those being evaluated.
    • The CoARA agreement operationalises both, committing signatories to a multi-year reform trajectory that recognises a diversity of outputs and moves away from inappropriate uses of metrics such as journal impact factor and h-index in individual assessment.

    Together these frameworks describe what responsible research metrics look like in practice: quantitative indicators used transparently, alongside — never instead of — qualitative judgement about actual contribution. A narrative CV is the assessment instrument that makes this operational at the level of an individual application or promotion case. It forces panels to read what someone actually did, rather than defaulting to citation counts or journal prestige as a shortcut.

    This matters because the responsible use of research metrics is not simply an ethical preference; it is increasingly a compliance requirement. Funders that have signed the CoARA agreement are expected to demonstrate progress against its commitments in periodic reporting, and institutional promotion committees are under growing scrutiny — from researchers, unions, and equality bodies — to show that assessment criteria do not systematically disadvantage early-career staff, caring responsibilities, or non-traditional research paths.

    Building an Adaptable Narrative CV Template for Your Institution

    Research administrators do not need to invent a format from scratch. A workable institutional template can be adapted directly from the UKRI structure, with three practical additions:

    • A CRediT-referenced contributions table. Alongside the narrative prose, ask applicants to tag their top outputs with CRediT roles. This gives panels an at-a-glance, standardised way to see contribution type without reading full narrative text for every output.
    • Explicit word or character limits per section. UKRI’s model works because it is bounded — typically around 250 words per contribution. Unbounded narrative sections tend to reproduce the same volume problem narrative CVs were designed to solve.
    • Panel training guidance, not just applicant guidance. The most common implementation failure is training applicants to write narrative CVs while leaving assessment panels to fall back on old habits — scanning for journal names and citation counts. Any template rollout should be paired with a short panel briefing on how to read and score narrative content consistently.

    Institutions adopting this approach should also publish a short worked example — a genuinely useful narrative CV academia example drawn from a real (anonymised or composite) case — alongside the template itself. Researchers consistently report that abstract guidance is far less useful than seeing one well-written section under each heading.

    What This Means for Research Administrators

    The practical implications for research administration offices are immediate and cut across several functions. Grants offices need to update internal application checklists so that narrative CV sections are reviewed pre-submission, since panels will reject applications that revert to a standard chronological CV. Promotion and tenure committees need updated criteria documents that explicitly reference contribution-based narrative rather than output count, with clear guidance on how CRediT-tagged contributions should be weighted. Research information systems (CRIS platforms) should be checked for the ability to export CRediT role data alongside publication records, since manually reconstructing contribution history for every grant round is not sustainable at scale.

    There is also a change-management dimension. Senior academics who built careers under metric-heavy assessment regimes may be the most resistant to narrative formats, viewing them as subjective or time-consuming. Framing the change around the Leiden Manifesto’s evidence base — that metrics-only assessment produces systematic distortions, including gaming behaviour and disincentives for open, collaborative, or translational work — tends to land better with sceptical audiences than framing built purely around funder compliance.

    A Direction of Travel, Not a Passing Trend

    Narrative CVs are not a temporary funder fashion. They are the assessment-level implementation of a decade-long reform movement running through DORA, the Leiden Manifesto, and now the CoARA agreement’s institutional commitments. As REF 2029 preparations accelerate and more funders align their application formats with UKRI’s approach, institutions that have already built adaptable templates, panel training, and CRediT-referenced contribution records will be better positioned than those treating each funder’s narrative format as a one-off compliance exercise. The practical work now sits squarely with research administrators: translate policy commitment into templates, guidance, and panel practice that researchers can actually use.