Pre-Award Research Administration
The Pre-Award Research Administration domain tests the work between a funding opportunity and an accepted award: finding and interpreting the solicitation, confirming eligibility, assembling the proposal, developing the budget, handling cost sharing and subawards, securing compliance approvals, and submitting through the sponsor system.
Core rules and concepts
- Read the notice of funding opportunity and sponsor policy. Eligibility, required forms, page limits, review criteria, cost-sharing rules, indirect-cost policy, and submission system are all controlling.
- Build direct costs that are allowable, allocable, reasonable, and consistently treated under 2 CFR 200.403. Do not include costs that belong to another project or that the sponsor disallows.
- Apply indirect costs correctly. Use the negotiated rate and base, or the sponsor cap if lower. If the entity has no negotiated rate and is eligible, the de minimis rate is 15% of modified total direct costs (MTDC).
- Distinguish mandatory, voluntary committed, and voluntary uncommitted cost sharing. Only committed cost sharing is documented and tracked; voluntary committed cost sharing included in the approved budget can become binding.
- Apply the subrecipient-versus-contractor test in 2 CFR 200.331. Obtain a scope of work, budget, commitment letter, and indirect-rate documentation for each subrecipient.
- Secure compliance approvals early: IRB or IACUC, conflict-of-interest disclosures, export-control review, recombinant DNA or biohazard review, and data-security review. Some are required at proposal; others are just-in-time.
- Submit through the authorized organizational representative after internal review and system validation.
Worked example
A sponsor limits indirect costs to 8% of total costs, but the institution has a negotiated 55% MTDC rate. Reasoning: follow the sponsor's cap, not the negotiated rate. Apply 8% to the sponsor's stated base and explain the limitation in the budget justification. Do not add the difference as a direct cost unless the sponsor expressly allows it. Also check whether cost sharing is required; if it is not, do not volunteer it merely to strengthen the proposal. The exam often tests whether you can separate the negotiated rate from the sponsor's cap.
Traps that cost marks
- Applying the negotiated F&A rate to a sponsor-capped budget.
- Treating every collaborator as a contractor without applying the 200.331 test.
- Missing a just-in-time compliance approval and assuming the award can be set up without it.