CASRAI Dictionary

Tag: federal grant compliance

  • AI Legislation Tracker: Free Tools Compared for Research Offices

    An AI legislation tracker is a curated, continuously updated resource that monitors the progress of artificial intelligence bills, statutes and regulations across jurisdictions. For research offices, three free options cover the ground a paid GRC subscription would otherwise charge for: the IAPP’s US State AI Governance Legislation Tracker for state-level bills, White & Case’s AI Watch for a global regulatory sweep, and the AI Act Explorer for line-by-line navigation of the EU AI Act. Used together, they give research administrators enough coverage to flag compliance and procurement risk without a dedicated legal-intelligence budget.

    An AI legislation tracker is a legal-intelligence tool — usually maintained by a law firm, professional association, or legislature — that indexes AI-related bills and regulations by jurisdiction, status and topic so non-specialists can monitor change without reading primary legislative text. For a research office, that means catching a new state disclosure requirement or an EU AI Act compliance deadline before it lands in an audit finding.

    Table of contents

    What is an AI legislation tracker, and why does a research office need one?

    Research offices sit at the intersection of three regulatory pressures: institutional AI-use policy, funder terms and conditions, and the AI laws of every jurisdiction in which their institution operates, procures software or receives funding. No single regulator publishes a consolidated feed of all three, which is why legal-intelligence trackers — built by law firms and associations to serve their own clients — have become the de facto public monitoring layer for everyone else.

    Three gaps make this monitoring hard for a research office specifically. First, state-level fragmentation in the US: MultiState.ai reported tracking 1,561 AI-related bills across 45 states in early 2026, and a bill’s status can change between a legislative session’s opening and a grant’s renewal date. Second, phased EU obligations: the AI Act (Regulation (EU) 2024/1689) entered into force on 1 August 2024 but applies in stages — prohibited-practice provisions since 2 February 2025, general-purpose AI model obligations since 2 August 2025, and the bulk of high-risk system obligations from 2 August 2026. Third, procurement-clause drift: institutional purchasing teams increasingly need to know whether a vendor’s AI tool falls under a “high-risk” classification before a contract is signed, not after.

    Comparing the free trackers: IAPP, White & Case AI Watch and the AI Act Explorer

    Each of the three core tools covers a different layer of the regulatory stack. None requires a paid subscription for the baseline tracker view, though firms use them as client-development tools, so update cadence and depth of legal commentary vary.

    Tool Publisher Geographic scope Best use for a research office Cost
    US State AI Governance Legislation Tracker IAPP US state legislatures Flagging new state disclosure/consumer-protection bills affecting AI-assisted research tools Free
    AI Watch: Global Regulatory Tracker White & Case US, EU, UK, China and other core markets Cross-jurisdiction horizon-scanning for institutions with international partners Free
    AI Act Explorer Future of Life Institute (artificialintelligenceact.eu) European Union Locating the exact article/annex governing a specific AI use case before procurement sign-off Free
    Artificial Intelligence Legislation Database National Conference of State Legislatures (NCSL) US state legislatures Official-source cross-check against law-firm trackers, filterable by policy topic Free
    OECD.AI Policy Navigator OECD 80+ countries and international bodies Global baseline for institutions with funders or partners outside the US/EU Free

    Two law-firm trackers rarely agree exactly on bill status, since each applies its own inclusion criteria — the IAPP chart, for example, deliberately excludes government-only AI bills to focus on rules affecting private-sector organisations. A research office should treat the NCSL database as the authoritative cross-check whenever a law-firm tracker and an internal compliance log disagree, since NCSL draws directly from legislative records rather than curated commentary.

    How to monitor AI law without a paid GRC subscription

    A practical monitoring routine needs three components: a jurisdiction list, a check cadence, and an escalation trigger. Map the institution’s actual footprint — states where staff or partner sites are located, countries with active funder relationships, and any EU-based collaborators — against the five tools above, rather than trying to watch all 45+ US states with active bills at once.

    • Set a monthly review of the IAPP tracker and NCSL database for the institution’s home state plus any state with a satellite campus or major subcontractor.
    • Set a quarterly review of White & Case AI Watch for jurisdictions tied to international grant or publishing partners.
    • Check the AI Act Explorer whenever procuring or renewing an AI-enabled research tool from an EU-based or EU-selling vendor, since Article 53 transparency obligations for general-purpose AI providers already apply.
    • Escalate to institutional counsel the moment a tracked bill moves from “introduced” to “enacted” in a jurisdiction on the footprint list — status changes, not initial filings, are the actionable signal.

    This cadence substitutes staff time for the subscription cost of a commercial GRC platform. It will not catch everything a paid legal-intelligence service would, but it closes the gap between “no monitoring” and “monitoring proportionate to institutional risk,” which is the realistic target for most research offices.

    Which AI rules actually affect grant compliance and procurement

    Not every tracked bill is relevant to a research office. The ones that matter cluster into two categories: funder-facing disclosure requirements and vendor/procurement obligations. On the funder side, publishers already require disclosure of generative-AI use in manuscript preparation under guidance from bodies such as ICMJE and COPE — a policy layer that sits alongside, not inside, the legislative trackers above, and one research offices should monitor through authorship policy channels rather than a legislation tracker.

    On the procurement side, the EU AI Act’s general-purpose AI model obligations — applicable since 2 August 2025 — require providers to maintain technical documentation and, for systemic-risk models, conduct model evaluations; institutions procuring AI research tools from in-scope vendors should expect updated contract terms reflecting this. Separately, under Article 57 of Regulation (EU) 2024/1689, each EU member state must establish at least one national AI regulatory sandbox operational by 2 August 2026 — a detail the AI Act Explorer surfaces clearly but general news coverage rarely mentions, and one that matters to institutions running EU-based pilot deployments of AI research tools.

    In the US, state consumer-protection style AI bills increasingly impose obligations on “deployers” as well as developers — meaning an institution using a third-party AI tool, not just the vendor that built it, can carry compliance obligations. This is the single most consequential fact a research office should extract from the state trackers: deployer obligations mean procurement due diligence, not just vendor selection, is now a compliance function.

    Common questions research administrators ask

    Are there any regulations on AI?

    Yes. There is no comprehensive federal AI statute in the United States, but individual US states have enacted targeted laws, the European Union’s AI Act (Regulation (EU) 2024/1689) is in force with phased obligations through 2027, and dozens of other jurisdictions maintain sector-specific or principles-based AI policy frameworks tracked by the OECD.

    Does Europe have AI regulations?

    Yes. The EU AI Act is the first comprehensive AI-specific legal framework, entering into force on 1 August 2024. Prohibited-practice rules applied from February 2025, general-purpose AI model obligations from August 2025, and most high-risk system requirements apply from August 2026 onward.

    Where are the AI regulations?

    AI rules are distributed across national statutes, EU regulation, and US state legislatures rather than one source — which is precisely why trackers such as IAPP’s state chart, White & Case’s AI Watch, and the AI Act Explorer exist: each consolidates one layer of a fragmented, multi-jurisdiction landscape into a single reference point.

    The regulatory landscape a research office must monitor will keep expanding rather than consolidating: more US states are expected to move bills from “introduced” to “enacted” through 2026 and 2027, and the EU AI Act’s remaining compliance deadlines run to August 2027. A footprint-mapped, tiered-cadence monitoring routine built on these five free trackers is a realistic, sustainable substitute for a paid GRC subscription — provided it is reviewed and re-scoped as the institution’s own AI use, partnerships and procurement expand.

  • Office of Grants Management vs Program Offices

    The Office of Grants Management is the part of a federal department — at the Department of Health and Human Services (HHS), the Office of Grants (OG), under the Assistant Secretary for Financial Resources (ASFR) — that sets department-wide policy, issues the Notice of Award, and enforces financial and compliance rules across every award. Individual program offices, by contrast, judge scientific and programmatic merit within their own subject area. Grantee institutions deal with both, for different reasons, throughout the life of an award.

    In one sentence: the Office of Grants Management is the administrative and financial authority that governs how federal grant funds are awarded, monitored, and closed out, while program offices decide what gets funded and why. HHS is the largest federal grant-making agency in the United States, and the distinction between its central grants office and its dozens of program offices is one of the most consistently misunderstood parts of the federal award lifecycle for institutional research administrators.

    What Does the Office of Grants Oversee?

    The HHS Office of Grants formulates department-wide grants policy and oversees its implementation across every HHS operating division. It does not decide which research or service proposals get funded; it decides how the resulting awards are administered, financed, and audited.

    According to a December 2023 U.S. Government Accountability Office review (GAO-24-106008), the Office of Grants “provides department-wide leadership on grants” and serves several government-wide roles beyond HHS itself. In January 2021, the Office of Management and Budget designated HHS to house the government-wide Grants Quality Services Management Office (Grants QSMO), which supports other federal agencies in adopting shared, standardised grants-management systems.

    • Developing and issuing department-wide grants policy, including the HHS Grants Policy Statement (GPS), last revised October 2024
    • Applying the Uniform Administrative Requirements, Cost Principles, and Audit Requirements codified at 45 CFR Part 75
    • Issuing the official Notice of Award (NoA) that legally obligates federal funds
    • Overseeing financial reporting, audit resolution, and closeout across all HHS awards
    • Running the Grants QSMO Marketplace, launched September 2022, which offers other agencies shared grants-management and payment platforms

    The scale is substantial: GAO reports the federal government distributed approximately $1.2 trillion in grants in fiscal year 2022 — roughly 19 percent of total federal spending, and over $400 billion more than FY 2019. HHS accounts for the largest share of any single federal grant-making agency.

    How Does the Office of Grants Differ From Program Offices?

    The core distinction is “how” versus “what.” The Office of Grants governs the administrative, financial, and regulatory mechanics of an award — eligibility of costs, reporting deadlines, audit requirements, closeout. Program offices — the National Institutes of Health institutes, the Health Resources and Services Administration bureaus, the Administration for Children and Families divisions, and similar bodies — set programmatic priorities, write the Funding Opportunity Announcement’s scientific or service requirements, and judge whether a grantee is meeting technical objectives.

    Function Office of Grants (Grants Management) Program Office
    Primary question answered Is this cost allowable and compliant? Is this science/service meeting its goals?
    Issues Notice of Award Yes No
    Sets scientific/programmatic scope No Yes
    Reviews financial/progress reports Financial reports, audit findings Technical/programmatic progress reports
    Governs closeout mechanics Yes Provides final technical sign-off
    Typical grantee contact Grants Management Specialist Project Officer / Program Officer

    Grantee institutions need two working relationships per award: a technical relationship with the program office’s project officer, and an administrative relationship with the grants management specialist. Sending a budget modification to a project officer instead of the specialist is a routine, avoidable source of delay.

    Where Does OASH’s Own Grants Function Fit In?

    A frequent source of confusion is the phrase “OASH Office of Grants Management.” The Office of the Assistant Secretary for Health (OASH) operates its own grants and cooperative agreements function, published at health.gov/grants, covering programmes such as Title X family planning and adolescent health initiatives that OASH itself administers.

    This is not a separate, competing authority to the department-wide Office of Grants under ASFR. OASH’s grants activity operates within the HHS-wide policy framework — the same Grants Policy Statement and 45 CFR Part 75 requirements apply — but OASH runs its own competitions, issues its own Funding Opportunity Announcements, and assigns its own grants management staff for the awards it makes. A grantee dealing with OASH therefore interacts with an OASH-specific contact who still answers to department-wide policy. This layered structure — one policy authority, multiple operating-division grants functions beneath it — is largely absent from generic explainer pages, which describe either the federal picture or a single state office, not HHS’s two-tier structure.

    Every accredited research institution maintains an institutional counterpart to the federal grants office: the sponsored programs office (sometimes called Office of Research Administration or Grants and Contracts). Its function mirrors the Office of Grants Management’s role, but from the recipient side.

    The sponsored programs office is the institution’s authorised signatory for award acceptance, its central point for compliance with 45 CFR Part 75 and OMB Uniform Guidance (2 CFR Part 200), and its liaison to the HHS grants management specialist rather than the program office’s project officer. Bodies such as the National Council of University Research Administrators (NCURA) and INORMS document this division of labour consistently: principal investigators own the science; the sponsored programs office owns the compliance interface. For a broader view of this interface within institutional research administration practice, see CASRAI’s research administration resources.

    What Happens at Closeout and With Cost Sharing?

    Two compliance touchpoints sit squarely with the Office of Grants Management rather than the program office: closeout and cost sharing.

    A grant closeout report is the set of final documents — the Federal Financial Report, the final progress report, and any property disposition report — that a recipient must submit once the period of performance ends. Under the Uniform Guidance framework that 45 CFR Part 75 incorporates for HHS awards, these reports are due within a fixed post-performance window, after which unspent funds are deobligated and the award is formally closed by the grants management office, not the program office.

    Cost sharing (sometimes called matching) is the portion of total project cost that the recipient institution — not the federal award — commits to fund, whether required by statute or offered voluntarily in the proposal. The Office of Grants Management verifies documented cost-sharing commitments were actually met before an award can close; a shortfall found at closeout is a grants-management finding, even when the project was scientifically successful.

    Frequently Asked Questions

    What does a grants manager do?

    A grants manager at a federal Office of Grants administers the financial and compliance lifecycle of an award: reviewing budgets, issuing the Notice of Award, monitoring reporting compliance, and processing closeout. This role is distinct from a project officer, who judges technical or scientific performance.

    What is the grant management function?

    The grant management function is the administrative infrastructure — policy, systems, and staff — that a funding agency uses to award, monitor, and close federal financial assistance. At HHS this sits with the Office of Grants under ASFR, applying the Grants Policy Statement and 45 CFR Part 75 across every operating division.

    What are common mistakes in grant management?

    The most common mistakes are routing compliance questions to a project officer instead of the grants management specialist, missing the fixed closeout deadline, and failing to document cost-sharing commitments contemporaneously rather than reconstructing them at award end.

    What are grant management services?

    Grant management services cover pre-award risk assessment, Notice of Award issuance, ongoing compliance monitoring, and closeout processing. HHS centralises much of this through its Recipient Data Insights tool, which automates pre-award risk scoring department-wide.

    Implications and Outlook

    For institutions holding HHS awards, the practical takeaway is structural, not procedural: two distinct offices govern every award, and each has authority the other cannot override. A program office cannot waive a 45 CFR Part 75 cost-allowability rule, and the Office of Grants Management cannot override a program office’s technical judgement on scientific merit.

    HHS’s modernisation record shows this split hardening rather than dissolving. The ReInvent Grants Management initiative (2017–2020) and the September 2022 Grants QSMO Marketplace launch both centralised administrative infrastructure further, while leaving programmatic decisions with the operating divisions. Institutions that route compliance questions to their sponsored programs office, and technical questions to the program office, will keep seeing faster processing than those that conflate the two.

  • Research Misconduct Investigations: How ORI and UKRIO Procedures Compare

    Grant administrators rarely encounter research misconduct allegations often — but when one arrives, the clock starts immediately, and the procedural path depends entirely on which side of the Atlantic the funding sits. A US Public Health Service (PHS) grant triggers a federally regulated process overseen by the Office of Research Integrity (ORI); a UK Research England or UKRI grant triggers an institution-led process shaped, but not enforced, by the UK Research Integrity Office (UKRIO). Confusing the two — assuming ORI’s binding timelines apply to a UK case, or that UKRIO can compel an outcome the way ORI can — is a common and costly error for administrators managing cross-border collaborations.

    This guide sets out, side by side, what each body actually is, how each defines misconduct, and how the investigation stages differ — so administrators handling an allegation tied to a grant know which rulebook applies.

    How ORI and UKRIO define research misconduct

    Both frameworks agree on a common core — fabrication, falsification, and plagiarism (FFP) — but they diverge sharply in scope.

    ORI operates under 42 CFR Part 93, the PHS Policies on Research Misconduct. Its definition is deliberately narrow: research misconduct means fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. A finding requires three elements to be met: a significant departure from accepted practices in the relevant research community; committed intentionally, knowingly, or recklessly; and proven by a preponderance of the evidence. Honest error and legitimate differences of scientific opinion are explicitly excluded.

    UKRIO, by contrast, works from a broader, non-statutory definition: “behaviours that deliberately or recklessly fall short of the standards expected in the conduct of research.” Its guidance, aligned with the UK Concordat to Support Research Integrity (Universities UK, 2019), extends beyond FFP to cover breaches of ethical approval, undeclared conflicts of interest, and mismanagement of research data — while also naming a distinct, lower-severity category, “questionable research practices” (QRPs), for avoidable errors that fall short of intentional misconduct.

    Regulator versus adviser: two different roles

    The most consequential difference is not definitional but structural: ORI is a federal oversight body; UKRIO is an independent charity with no regulatory power.

    • ORI sits within the US Department of Health and Human Services and directly oversees how institutions handle misconduct allegations tied to PHS-funded research (including NIH grants). It can conduct its own oversight review of an institution’s findings, recommend administrative actions, and refer findings to the HHS Departmental Appeals Board.
    • UKRIO was established as an independent advisory charity in 2006. It publishes a model investigation procedure that UK research organisations may adopt or adapt, offers case-by-case advice, and promotes good practice — but it does not investigate cases itself, does not mandate a single national procedure, and has no statutory sanctioning power.

    UK funders address this gap contractually rather than through a regulator. UKRI’s Guidance for Research Organisations on the Investigation of Research Misconduct (April 2025) requires any organisation receiving UKRI funding to investigate allegations against staff or students under its own Grant Terms and Conditions, with UKRI able to take funding action if an organisation fails to do so.

    How an investigation actually runs, stage by stage

    Both systems separate a preliminary triage stage from a full inquiry, but they name and time these stages differently.

    Stage ORI (US, PHS-funded research) UKRIO model (UK institutions)
    Trigger Allegation received by institution’s Research Integrity Officer Concern raised with a “Named Person” or responsible officer
    Triage Assessment: does the allegation meet the FFP definition and involve PHS funding? Initial assessment: does it fall within the misconduct procedure’s scope?
    Formal fact-finding Inquiry (institution-level, time-limited) Initial investigation to establish if there is a case to answer
    Full review Investigation, following a sufficient inquiry finding Full investigation by an academic panel, including external members
    Standard of proof Preponderance of the evidence Not codified nationally; set by each institution’s procedure
    External oversight ORI oversight review of institutional findings; report to PHS agency None mandatory; UKRIO offers advice only
    Appeal route HHS Departmental Appeals Board Institutional appeal, managed by someone other than the original Named Person

    Under the UKRIO model, once a panel reports its findings, the Named Person decides on next steps: referral to institutional disciplinary proceedings, correction of the published record, and notifying relevant funders. Where allegations are not upheld, the same procedure is meant to protect the reputation of the person accused — a feature both systems share in principle, though neither publishes comparable statistics on false-allegation rates.

    Answer-first: common questions on research misconduct

    What are the three types of research misconduct?

    Both ORI and most UK institutional policies converge on the same core triad: fabrication (inventing data or results), falsification (manipulating research materials, equipment, or data to misrepresent results), and plagiarism (using another person’s ideas, processes, or words without credit). This is often abbreviated FFP.

    What are some examples of research misconduct?

    Common examples include inventing patient consent records, selectively deleting inconvenient data points, copying text or images from another paper without attribution, and misrepresenting the outcome of a statistical test. UKRIO guidance also treats proceeding without required ethical approval as a form of misconduct, even without FFP intent.

    What counts as research misconduct?

    Conduct counts as misconduct when it represents a significant, intentional or reckless departure from accepted research standards — not an honest mistake or a genuine scientific disagreement. ORI requires proof by a preponderance of the evidence; UKRIO-aligned institutions apply a similar intent-based threshold under their own procedures.

    What this means for research administrators

    For administrators managing grants that cross jurisdictions — a common scenario in NIH-funded international collaborations or Horizon Europe partnerships involving UK institutions — three practical points follow from the comparison above:

    • Know which body has enforcement power. Only ORI can conduct oversight review and refer a case to a federal appeals process; UKRIO cannot compel an institutional outcome.
    • Check the funder’s own reporting clause. UKRI’s April 2025 guidance obliges the receiving institution — not UKRIO — to investigate and report; PHS grant terms impose parallel obligations that run through ORI.
    • Do not assume a single global timeline. ORI-regulated inquiries and investigations run to defined federal timeframes; UKRIO-aligned UK procedures are set institution by institution, so the applicable deadline sits in the local Code of Practice for Research, not in UKRIO’s own documents.

    Administrators supporting research administration functions across both systems should hold copies of both the relevant institutional misconduct procedure and the specific grant terms — the procedural detail, not the high-level definition, is where jurisdictional mismatches cause delay.

    Where the two systems are heading

    Both frameworks are converging on the same underlying principle even as their governance models remain distinct: misconduct findings should correct the scholarly record, not just discipline an individual. UKRI’s 2025 guidance tightened institutional reporting obligations, and ORI continues to publish case summaries and administrative actions as a transparency mechanism. Neither change closes the structural gap — one system regulates, the other advises — so for the foreseeable future, administrators handling cross-border allegations will need to work both playbooks rather than assume one substitutes for the other.

    As with contributor-role standards, where CASRAI originated the CRediT taxonomy in 2014 and the standard is now stewarded by NISO as ANSI/NISO Z39.104-2022, research integrity governance illustrates a broader pattern in research administration: originating bodies and enforcement bodies are frequently separate, and knowing which is which is a prerequisite for compliant practice.

  • cOAlition S EU-Funded Projects: What Horizon Europe Grantees Must Still Do

    Search “cOAlition S EU-funded projects” and you land on a page that is easy to misread. It does not list the projects cOAlition S funds for grantees — it lists the European Commission grants that fund cOAlition S itself. That distinction matters for research administrators trying to work out which obligations actually attach to a Horizon Europe grant, and which belong to the separate, funder-driven Plan S mandate that the European Commission helped create.

    This piece reads that page on its own terms, then answers the practical question institutions actually have: given that the European Commission’s own Horizon Europe open access mandate already exists, where — if anywhere — does cOAlition S add anything a grantee still has to act on?

    What “EU-Funded Projects” Actually Lists on cOAlition S’s Site

    cOAlition S’s “EU-funded projects” resource page catalogues five Horizon Europe and Horizon 2020 grants awarded to the European Science Foundation and partner consortia to build the infrastructure and evidence base around Plan S — it is not guidance aimed at individual grant recipients. Each entry names the funding call, the EU contribution, the duration and the coordinating institution.

    Project Funded under EU contribution Duration Coordinator
    OA-Advance HORIZON.4.2 €132,000 2024–2025 European Science Foundation (France)
    SOAR H2020-EU.5.e. €299,930 2020–2023 European Science Foundation (France)
    DIAMAS HORIZON-WIDERA-2021-ERA-01-43 €3,000,000 2022–2025 Aix-Marseille University (France)
    CRAFT-OA HORIZON-INFRA-2022-EOSC-01-02 €5,000,000 2023–2028 University of Göttingen Library (Germany)
    PALOMERA HORIZON-WIDERA-2022-ERA-01-42 €2,000,000 2023–2025 OPERAS (Belgium)

    The through-line is instructive: the European Commission is not a passive observer of Plan S. It is a funding partner for the studies (OA-Advance’s independent review of Plan S impact), tools (SOAR’s support for identifying compliant venues) and Diamond open-access infrastructure (DIAMAS, CRAFT-OA, PALOMERA) that keep the mandate operable. That funding relationship is the real answer to how cOAlition S and Horizon Europe are connected — and it is the fact most generic summaries of Plan S skip entirely.

    How cOAlition S and the Horizon Europe Mandate Overlap

    The European Commission is itself a cOAlition S member, alongside national funders including several that fund UK-based and other associated-country researchers, and the Horizon Europe open access mandate is, in substance, the Commission’s own implementation of Plan S principles inside its Model Grant Agreement. Both frameworks require:

    • Immediate open access to peer-reviewed publications, with no embargo period.
    • Deposit of the publication, or the accepted manuscript, in a trusted repository at the time of publication.
    • A Creative Commons Attribution (CC BY) licence, or equivalent, on journal articles and conference papers.
    • Author retention of sufficient rights to comply, regardless of what a publisher’s default policy allows.

    Because these baseline requirements are shared, a grantee who satisfies the Horizon Europe Model Grant Agreement’s open access clause will, in almost all cases, also satisfy Plan S. This is why cOAlition S materials describe Horizon Europe as an aligned implementation rather than a competing regime.

    Where cOAlition S Rules Still Add to the Horizon Europe Baseline

    Alignment is not identity. Three areas where the two frameworks are not simply interchangeable deserve attention from institutional research offices.

    Scope beyond the grant. Plan S is a funder mandate: it binds a researcher’s Plan-S-relevant output for as long as they hold funding from a cOAlition S member, not only the outputs tagged to a single Horizon Europe grant number. A researcher holding both a Horizon Europe grant and, say, a Wellcome or Research Council of Norway award is subject to the combined Plan S obligations of every cOAlition S funder involved — the Horizon Europe clause alone does not cover that.

    The compliance route. cOAlition S operationalises compliance through the Journal Checker Tool, which tells an author whether a specific journal, for their specific funder and affiliation, satisfies the mandate via the fully open access “Gold” route, a compliant transformative agreement, or the self-archiving Rights Retention Strategy route. The Horizon Europe Model Grant Agreement states the requirement; the Journal Checker Tool is the operational instrument grantees actually use to verify a chosen venue — and it is a cOAlition S resource, not an EC one.

    Article Processing Charges in hybrid venues. Horizon Europe funding rules do not reimburse APCs for publishing in hybrid journals — subscription titles that also sell open access on a per-article basis — only in fully open access journals or platforms, including the Commission’s own Open Research Europe platform. Plan S’s broader principle is the same, but grantees who assume “my publisher offered an open access option” is automatically fundable frequently discover the hybrid exclusion applies regardless of which mandate they cite.

    Common Questions from Grantees

    What is an EU funded project?

    An EU-funded project is a research or coordination activity receiving a grant from a European Union programme such as Horizon Europe or its predecessor, Horizon 2020. In cOAlition S’s own case, five such projects — OA-Advance, SOAR, DIAMAS, CRAFT-OA and PALOMERA — fund the coalition’s open access infrastructure and evidence base, not individual researchers’ compliance.

    Can the UK apply for EU funding?

    Yes. The UK re-associated to Horizon Europe from January 2024, meaning UK-based researchers can again apply for and hold Horizon Europe grants directly. UK recipients follow the same open access mandate as any other beneficiary, alongside any separate Plan S obligations from UK funders such as UKRI or Wellcome.

    Is cOAlition S the same body as the European Commission?

    No. cOAlition S is a voluntary alliance of national and private research funders, of which the European Commission is one member among roughly two dozen. The Commission sets Horizon Europe’s own grant conditions independently, but has aligned them closely with Plan S principles as part of that membership.

    Do Horizon Europe grantees need to follow Plan S separately from their grant agreement?

    Usually not in substance, since the Horizon Europe Model Grant Agreement already embeds Plan S’s core requirements. Grantees should still check Plan S obligations separately whenever a co-funder, prior grant, or institutional mandate outside Horizon Europe applies to the same publication.

    A Practical Compliance Checklist

    For research offices triaging a Horizon Europe-funded manuscript against both frameworks, the practical questions are the same regardless of which document a grant officer cites:

    1. Does the venue offer immediate open access with no embargo — checked directly, not assumed from the journal’s general reputation?
    2. Is a CC BY licence (or CC BY-NC / CC BY-ND for a monograph) applied to the published or accepted version?
    3. Has the author retained rights to deposit the accepted manuscript, independent of the publisher’s standard licence terms?
    4. If the venue is hybrid, has the team confirmed the APC is not eligible for reimbursement under Horizon Europe rules before committing funds?
    5. Do any other cOAlition S funders co-fund the same output, requiring a combined compliance check beyond the Horizon Europe grant alone?

    What This Means for Institutions

    The practical risk is not that Horizon Europe and Plan S conflict — it is that research offices treat “we’re Horizon Europe funded, so we’re covered” as a substitute for checking the venue, licence and co-funder picture on each output. Teams that build Journal Checker Tool and rights-retention verification into submission workflows, rather than relying on the Model Grant Agreement clause as a proxy, catch hybrid-APC and multi-funder edge cases before they become a post-award finding.

    For teams supporting research administration workflows across multiple funders, the EU-funded projects underpinning cOAlition S’s own infrastructure — particularly DIAMAS and CRAFT-OA’s work on Diamond open access publishing — are also worth tracking directly, since they signal where funder-preferred, no-fee publishing routes are likely to expand over the current Horizon Europe programming period.

    Outlook

    With DIAMAS and CRAFT-OA running through 2025 and 2028 respectively, and OA-Advance’s independent review due to feed recommendations on what comes after Plan S, the EU-funded projects on cOAlition S’s own page are best read as a forward signal rather than a static resource list. Institutions tracking them alongside their Horizon Europe grant terms — rather than treating the two frameworks as separate compliance tracks — will be better placed as Diamond open access infrastructure matures and funder mandates converge. CASRAI’s open research terminology reference provides further grounding for related definitions.

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

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

    What the 2 CFR 200 Cost Principles Actually Require

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

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

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

    The 2026 OMB Proposed Rule: What Changes for Allowability

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

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

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

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

    Allowable vs Unallowable Costs: Current Guidance vs the 2026 Proposal

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

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

    Cost Principles: Direct Answers to Common Questions

    What are the 4 cost principles?

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

    What are the three elements of 2 CFR Part 200?

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

    What is the 2 CFR 200 standard?

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

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

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

    Implications for Research Administrators and Institutions

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

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

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

    What Happens Next

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