CASRAI Dictionary

Tag: effort reporting

  • NIH Grants Policy Statement: What It Requires of Institutions

    The NIH Grants Policy Statement (NIHGPS) is the master terms-and-conditions document for every NIH award: institutions that accept NIH funding are bound by its rules on cost allowability, effort reporting, prior-approval triggers and audit obligations, applied alongside the government-wide cost principles in 2 CFR Part 200. Research administrators use it as the single reference point for what a grant actually obliges a recipient organisation to do.

    The NIH Grants Policy Statement is defined by NIH as the document that “makes available, in a single document, the policy requirements that serve as the terms and conditions of NIH grant awards.” It is not optional guidance — by accepting a Notice of Award, an institution agrees to comply with it unless the notice itself states otherwise.

    What is the NIH Grants Policy Statement?

    The NIHGPS is NIH’s consolidated statement of the terms and conditions attached to every grant, cooperative agreement and, where applicable, contract-adjacent award it issues. It is organised into three parts: general information about NIH and the award lifecycle, the substantive terms and conditions that bind recipients, and a directory of NIH contacts for compliance questions. Institutions do not negotiate these terms award-by-award; the current NIHGPS edition applies by reference from the date on the Notice of Award.

    Because the NIHGPS is revised periodically rather than rewritten from scratch, most institutional research offices track it as a living reference — checking each Notice of Award against the edition in force, since older awards can remain subject to the NIHGPS version current on the date they were issued.

    How does the NIHGPS relate to 2 CFR 200?

    The NIHGPS does not operate in isolation. It sits beneath, and explicitly incorporates, the Office of Management and Budget’s Uniform Guidance at 2 CFR Part 200 — the government-wide cost principles, administrative requirements and audit rules that apply to all US federal grants, not just NIH’s. The NIHGPS then layers NIH-specific interpretation and additional conditions on top of that baseline.

    There is also a departmental layer in between: the HHS Grants Policy Statement, issued by the Department of Health and Human Services, sets terms common to all HHS operating divisions. NIH’s own document tells recipients to consult the HHS Grants Policy Statement for department-wide matters and the NIHGPS for anything NIH-specific — the two are complementary, not duplicative.

    Document Issuing body Scope
    2 CFR Part 200 (Uniform Guidance) Office of Management and Budget Government-wide cost principles and audit requirements for all federal awards
    HHS Grants Policy Statement Department of Health and Human Services Department-wide terms across all HHS operating divisions
    NIH Grants Policy Statement National Institutes of Health NIH-specific terms and conditions layered on the two frameworks above

    What must institutions do to comply?

    Three compliance areas generate the most work for research administration offices: cost allowability, effort reporting, and the award terms that trigger prior approval.

    Cost allowability

    Costs charged to an NIH award must be allowable, allocable, reasonable and consistently treated, per the cost principles in 2 CFR 200 Subpart E, as applied through the NIHGPS. Institutions are expected to maintain financial management systems capable of tracking costs at the individual-award level and reconciling them through periodic Federal Financial Reports.

    Effort reporting

    Where NIH funds pay any part of a researcher’s salary, the institution must certify that the proportion of effort charged reflects the effort actually devoted to the project, consistent with the compensation-for-personal-services standard at 2 CFR 200.430. NIH also applies an annual salary cap, set against Executive Level II of the federal executive pay scale, that limits the salary rate chargeable to NIH awards regardless of an individual’s actual institutional salary.

    Award terms and prior approval

    The NIHGPS lists specific actions that require NIH’s prior written approval before an institution can proceed — commonly a significant change in project scope, a change of principal investigator, a no-cost extension beyond the automatic first extension, or the addition of a foreign component. Institutions that expend federal awards above the Single Audit threshold — raised to $1,000,000 under OMB’s 2 CFR 200 revision effective for fiscal years beginning on or after 1 October 2024 — must also arrange an annual Single Audit.

    • Maintain auditable, award-level financial records under 2 CFR 200 cost principles
    • Certify effort for NIH-funded personnel and apply the current salary cap
    • Seek prior approval for scope changes, PI changes, extensions and foreign components
    • Comply with human subjects, animal welfare, research misconduct and conflict-of-interest policies
    • Report inventions arising from NIH funding under Bayh-Dole Act procedures
    • Meet NIH data-sharing and public-access requirements for funded research outputs

    What changed for FY2026?

    NIH published a revised NIHGPS effective March 2026, applicable to awards issued for Fiscal Year 2026. Research offices should treat each Notice of Award as the definitive marker of which NIHGPS edition governs that specific award, since NIH does not retroactively apply every revision to awards already in force. Comparing the March 2026 edition against the prior version — rather than assuming continuity — is the safest institutional practice each cycle.

    Answer-first Q&A

    Who can apply for an NIH grant?

    Most NIH programmes do not require applicants to hold a specific degree or US citizenship; eligibility is set at the level of the individual funding opportunity. Institutions, not individuals, are the formal recipients of NIH awards, and it is the institution that assumes NIHGPS compliance obligations on behalf of its research staff.

    Can non-US citizens apply for NIH grants?

    Yes. Non-US institutions and researchers can serve as recipients or principal investigators for most NIH mechanisms, though some programmes impose citizenship or residency conditions stated explicitly in the funding opportunity notice. The NIHGPS applies equally to foreign and domestic recipient organisations once an award is made.

    What are the NIH guidelines referenced in grant compliance?

    “NIH guidelines” typically refers to specific technical policies — such as those governing recombinant DNA research — that sit alongside, but are distinct from, the NIHGPS. The NIHGPS is the umbrella terms-and-conditions document; specialised guidelines are incorporated into it by reference where relevant to a given award.

    What is a Type 3 NIH award?

    A Type 3 award is an administrative supplement: additional funds provided during a current project period to cover increased costs within the existing, peer-reviewed scope of work. It cannot extend the award beyond its current end date and is governed by the same NIHGPS terms as the parent award.

    What this means for research administration offices

    For grants and contracts offices, the practical implication is that NIHGPS compliance cannot be delegated to a single reading at award setup. Cost allowability rules, effort-reporting certification cycles and prior-approval triggers recur throughout an award’s life, and each NIHGPS revision can shift specific thresholds or procedures without changing the document’s overall structure. Institutions that build compliance checklists against the current NIHGPS edition — cross-referenced to 2 CFR 200 and the HHS Grants Policy Statement — reduce the risk of disallowed costs and audit findings.

    This layered structure (OMB, HHS, NIH) is a useful model for research administrators more broadly: understanding how a funder-specific policy statement incorporates broader federal cost and audit frameworks is a transferable skill across other US federal sponsors, not just NIH. CASRAI’s research administration content covers this compliance-mapping approach across funders.

    Looking ahead

    NIH continues to revise the NIHGPS on a rolling basis rather than a fixed annual schedule, and institutions should expect further alignment with OMB’s evolving Uniform Guidance, particularly around audit thresholds and data-sharing expectations. Research administration offices that treat the NIHGPS as a living compliance map — rather than a document read once at onboarding — are best positioned to absorb each revision without disruption to active awards.

  • 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.