CRA (Other exams): The Deadline That Moved: A Multi-Institution Proposal With a Missing Subaward Budget

The highest-risk items are not the science; they are the subaward documentation, the placeholder budget, the verbal cost share, and the unsupported new aim. I would sequence actions by dependency: first, call the subawardee's backup sponsored-programs contact and its CFO; ask for a budget using its federally negotiated indirect rate, a signed letter from an authorized official, and a biosketch. Second, tell Dr. Alvarez in writing that a placeholder amount is not an option because the budget is a representation of actual costs and can create a false statement; if the subawardee cannot deliver by the internal deadline, we must either descope the subaward or move to the next cycle. Third, remove the 5% technician cost share from the budget and narrative; voluntary committed cost sharing is prohibited and the technician is already fully charged to another federal award, so counting that time would double charge. Fourth, ask Dr. Alvarez to either obtain a letter and effort commitment from the national-lab collaborator or delete the new aim. I would escalate to the director if the PI insists on submitting incomplete or inaccurate information. The program officer cannot waive the sponsor's submission requirements, and an internal deadline exists to catch exactly these defects.

A placeholder is not a neutral convenience. The subaward budget is part of the proposal and must reflect the subawardee's actual costs, indirect rate, and committed effort; inserting $250,000 without a basis can mislead the sponsor and create a false institutional representation. It also creates a post-award problem: if the award is made, the subawardee may not be able to justify that amount, and rebudgeting or reducing it may require prior approval. The compliant options are: (1) obtain a draft budget and signed letter from the subawardee's backup official before the internal deadline; (2) if the subaward is not essential to the aims, remove it and have the collaborator participate as an unfunded consultant only if the sponsor allows and the collaborator agrees in writing; or (3) defer submission to the next cycle. Federal sponsors rarely extend deadlines for missing subaward documents. I would document all attempts, keep the PI informed, and not sign off on a budget I know is invented. If the PI wants to submit anyway, the director-not the RA-should make that call, and it should be documented.

Cost share: the chair's verbal promise is not an allowable cost-share commitment. The sponsor prohibits voluntary committed cost sharing, so even mentioning it in the budget or narrative can create an audit obligation. More fundamentally, the technician is already 100% charged to another federal award; cost sharing the same time would double charge the federal government. If the chair wants to contribute, the department would need to reassign actual effort to a non-federal account and record it in the ledger as uncommitted cost share-not claim it. New aim: adding a collaborator who has not agreed to participate is a scope and commitment problem. A federal proposal must not list an unwilling collaborator or imply a commitment that does not exist. The PI should either secure a signed letter, biosketch, and budget for the collaborator, or remove the aim. If the aim is central to the science, the honest choice is to delay to the next cycle. The RA's role is to protect the institution from a false submission, not to make the deadline at any cost.