Post-Award Research Administration
The Post-Award Research Administration domain tests what happens after the award notice: accepting and interpreting terms, setting up accounts, spending within the period of performance, obtaining prior approvals, documenting effort, issuing and monitoring subawards, submitting reports, and closing out.
Core rules and concepts
- Compare the award terms with the proposal and institutional policy. Note restrictions, reporting dates, intellectual property and data-rights terms, and prior-approval requirements.
- Set up the project correctly: budget load, project dates, cost-share accounts, and subaward accounts. Only allowable costs incurred within the period of performance may be charged.
- Know when prior written approval is required. 2 CFR 200.407 lists actions such as a change in scope, change in key personnel, PI absence for more than three months or a 25% reduction in effort, certain rebudgeting, and subaward changes. Expanded authorities may waive some items, but not all.
- Document personnel costs under 2 CFR 200.430(i). Charges must be based on records that accurately reflect work performed and be supported by internal controls; budget estimates alone are not sufficient.
- Issue subawards only after risk assessment and with a clear scope, budget, and reporting schedule. Monitor subrecipient progress and expenses; do not pay a subrecipient as if it were a vendor.
- Submit progress, financial, invention, and property reports on time. Close out within 120 days after the end date under 2 CFR 200.344.
Worked example
In month 10, a PI asks to move $40,000 from supplies to a new foreign subaward. Reasoning: adding a subaward can be a change in scope, and a foreign subaward may require additional risk review, export-control review, and sponsor approval. The rebudgeting threshold may also require prior approval. Check the award terms and 2 CFR 200.407 before processing. The correct answer is not to move the funds first and ask later; it is to determine whether approval is required, obtain it if needed, and document the change.
Traps that cost marks
- Processing cost transfers late or solely to clear an overdraft.
- Charging expenses after the end date without an approved extension.
- Missing a carryover restriction or a sponsor-specific prior-approval requirement.