Time & Effort Reporting: Federal Grant Requirements

What the audit record shows: Grantsights analysis of Single Audit findings in the Federal Audit Clearinghouse (opens in a new tab) found 1,648 findings for fiscal years 2022 through 2024 that cite 2 CFR 200.430 or time-and-effort documentation for payroll, and 269 of them (about 1 in 6) describe salaries charged from budgets, estimates or fixed percentages rather than actual time. Method: on October 18, 2026 we pulled every FAC finding text for audit years 2022 to 2024 that mentions "200.430" or "time and effort," dropped 20 that never mention payroll, salaries, wages, employees or personnel, and counted the rest by audit year and by what the auditor described. At least two of the organizations, Converge, Inc. and The Atlanta Botanical Garden, already had a time or wage tracking tool; what they lacked was the step that turns time records into salary charges. So settle payroll distribution, the after-the-fact true-up, who certifies, and rules for split-funded staff before you shop for effort-reporting software. For example, a nonprofit with one federal award can use a simple signed activity record if it covers total compensated activity and matches payroll, while a university with many awards needs a tighter certification workflow.

If you're a PI, grants administrator, or sponsored programs officer responsible for time and effort reporting on federal grants, this guide is for you. Whether you work at a university with $500 million in sponsored research or a small nonprofit with a single $150,000 award, the rules are the same: you must prove that every dollar of salary charged to a federal award reflects work that was actually performed on that award.

This isn't optional, and it isn't just paperwork. Salary and fringe benefit costs are a large share of most grant budgets, which means effort reporting errors translate directly into large dollar findings during audits. According to the HHS Office of Inspector General audit report on New York Medical College (May 2024), the college had used budget estimates instead of actual activity to claim $7.5 million in salaries, fringe benefits and indirect costs on NIH awards, and it flagged $7,469,306 as unsupported pending NIH's decision (report A-04-20-03583 (opens in a new tab)). That's what happens when effort reporting breaks down.

This guide covers exactly what 2 CFR 200.430 requires, how to build a compliant system, and the mistakes that get organizations into trouble.

What "Effort" Actually Means Under 2 CFR 200.430

Effort is not hours. This is the single most misunderstood concept in federal grants compliance.

For salaried employees, effort is the proportion of total professional activity devoted to a specific project, expressed as a percentage. If a principal investigator devotes 30% of their total working time to an NIH grant, that's 30% effort, whether they worked 40 hours that week or 70 hours. The denominator is always total compensated activity, and the numerator is the portion spent on a particular award.

For hourly (non-exempt) employees, time records based on actual hours worked are required. These employees report hours, not percentages.

This distinction matters because it drives how you build your reporting system, how you train employees, and what documentation auditors expect.

The 100% Rule

Total effort must always equal 100%. Always. If an employee is paid from three grants and also does administrative work, the percentages charged to each activity must sum to 100% of their compensated time. There's no such thing as 110% effort in a compliant system.

Here's what a properly documented effort distribution looks like:

If this employee's salary is $120,000 per year, you'd charge $48,000 to the NIH grant and $30,000 to the NSF grant. The remaining $42,000 comes from institutional funds covering administration and teaching.

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What Changed: From OMB Circulars to Uniform Guidance

Before December 26, 2014, effort reporting rules varied by organization type:

The Uniform Guidance (2 CFR Part 200) consolidated all three circulars into a single set of rules effective December 2014. The biggest change was eliminating the prescriptive methods. Instead of mandating PARs or specific certification formats, it sets standards that any system must meet. Since the 2024 revision they sit in 2 CFR 200.430(g)(1); before that they were in 200.430(i). According to 2 CFR 200.430(g)(1), charges to federal awards must be based on records that accurately reflect the work performed, and those records must:

1. Be supported by a system of internal control that gives reasonable assurance charges are accurate, allowable, and properly allocated
2. Be part of the organization's official records
3. Reasonably reflect the total activity the employee is paid for, not exceeding 100% (for universities, the institutional base salary)
4. Cover federal and all other paid activities on an integrated basis
5. Follow the organization's established accounting policies and procedures
6. Support how salary is split when someone works on more than one award or cost objective
7. Not rest on budget estimates alone: estimates can carry interim charges only with after-the-fact review and adjustments
8. Be allowed to show activity as a percentage distribution of total activities
9. For universities, not require a precise split, because teaching, research, service, and administration are intermingled

Per 2 CFR 200.430(g)(3), hourly (nonexempt) employees also need records of the total hours worked each day, and states, local governments, and Indian tribes can use substitute systems such as random moment sampling when their cognizant agency approves them (200.430(g)(5)).

This was a meaningful improvement. Under A-21, many universities were locked into paper-based PAR systems that generated mountains of forms but didn't necessarily improve accuracy. The Uniform Guidance opened the door to electronic systems and alternative methodologies that can actually work better while costing less to administer.

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The Two Core Documentation Approaches

Even though 2 CFR 200.430 doesn't mandate a specific format, most organizations use one of two approaches.

After-the-Fact Effort Certifications

This is the most common approach, especially at universities and large nonprofits. Here's how it works:

1. Payroll runs based on budgeted effort. When a grant is set up, salary charges are distributed according to the budget. If the budget shows 40% effort for a PI, the payroll system charges 40% of their salary to that grant each pay period.
2. At the end of each reporting period, the employee (or someone with firsthand knowledge) reviews the charges. They certify that the distribution of salary charges reasonably reflects how they actually spent their time.
3. If actual effort differs from the payroll charges, cost transfers are processed. The certification becomes the controlling document, and payroll records are adjusted to match reality.

Reporting periods typically align with semesters (for academic institutions) or quarters (for nonprofits and government entities). The certification must be completed by someone who has firsthand knowledge of the work performed. For principal investigators, that's usually the PI themselves. For support staff, it's typically their direct supervisor.

Personnel Activity Reports (PARs)

PARs are detailed records completed during or immediately after each reporting period. They document how an employee distributed their time across all activities. While no longer required by name under the Uniform Guidance, many smaller organizations still use PARs because they're straightforward and well understood by auditors.

A PAR typically includes:

• Employee name and position
• Reporting period dates
• List of all activities with percentage of effort
• Signature of the employee or knowledgeable supervisor
• Date of certification

The advantage of PARs is simplicity. The disadvantage is that they can become a compliance burden when you're managing hundreds of employees across dozens of awards.

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Institutional Base Salary: The Denominator That Controls Everything

For universities and research institutions, institutional base salary (IBS) is a concept that determines how effort percentages translate into dollar amounts. The definition now sits in 2 CFR 200.430(i)(2) (opens in a new tab)(2)), which reads: "IBS is the annual compensation paid by an IHE for an individual's appointment, whether that individual's time is spent on research, instruction, administration, or other activities. IBS excludes any income an individual earns outside of duties performed for the IHE." The same paragraph says charges to a federal award may not exceed the proportionate share of IBS for the period, unless the agency gives prior approval.

Here's why this matters: NIH caps salary charges at the Executive Level II rate, which NIH notice NOT-OD-26-034 (opens in a new tab) set at $228,000, effective January 1, 2026 after the correction in NOT-OD-26-038 (opens in a new tab). If a professor earns $280,000 but NIH only allows charges up to $228,000, you calculate effort percentages based on the full $280,000 IBS, but cap the dollar amount charged to the NIH grant.

Example:

• IBS: $280,000
• Effort on NIH grant: 50%
• Calculated charge: $280,000 x 50% = $140,000
• NIH salary cap: $228,000 x 50% = $114,000
• Actual charge to NIH grant: $114,000
• Institutional responsibility: $26,000 (the difference)

Outside income never counts toward IBS. How your institution treats other pay, such as incidental or extra service pay, depends on written policy that 200.430(i)(1)(ii) and (i)(4) require you to have. A common mistake is letting each department decide what's in the base: getting this definition wrong cascades through every effort calculation for that employee.

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Split-Funded Employees: Where Things Get Complicated

Employees funded by multiple sources are where effort reporting systems earn their keep. A program coordinator who spends time on three different grants and also does general admin work requires careful documentation.

Best Practices for Split-Funded Employees

Set up payroll correctly from the start. Use the grant budget as your initial distribution, but build in a process for periodic review. If someone is budgeted at 30% on Grant A and 20% on Grant B, start payroll at those percentages and adjust based on actual activity at each certification period.

Train employees to think in percentages, not hours. A common mistake is telling a split-funded employee to log 12 hours to Grant A and 8 hours to Grant B in a 40-hour week. For salaried employees, that's the wrong framework. Instead, they should estimate what proportion of their total professional effort went to each activity during the reporting period.

Watch for minimum effort thresholds. Many federal agencies have rules about minimum effort commitments. NIH, for example, requires that PIs on research grants devote measurable effort to the project. If a PI certified 0% effort for a reporting period but the grant was active and spending was occurring, that's a problem.

Process cost transfers promptly. 2 CFR 200.430(g)(1)(vii)(B) lets your written policy define what counts as a significant change in work activity, and says short-term swings of a month or two don't need adjusting if the distribution is reasonable over the longer term. So pick a variance threshold, write it down, and transfer the cost whenever a certification crosses it. For NIH awards, the NIH Grants Policy Statement section 7.5 (opens in a new tab) says error-correcting transfers should be made within 90 days of when the error was discovered, with documentation that fully explains how it happened and a certification from a responsible official. "To correct error" isn't an explanation.

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Documenting Cost Sharing Through Effort

Many federal grants include cost sharing or matching requirements, and a large portion of that cost sharing comes in the form of contributed effort. If your grant budget commits to 10% PI effort as cost sharing, you need to document that effort just as rigorously as you document effort that's directly charged.

Under 2 CFR 200.306 (opens in a new tab), cost sharing must be verifiable from the recipient's records, not from federal sources, and must be necessary and reasonable for project objectives. For effort-based cost sharing, this means:

• The effort must appear on the employee's effort certification at the committed percentage
• Payroll records must show the salary was paid from non-federal sources
• The dollar value must be calculated using the employee's actual IBS
• The cost sharing must be reported in financial reports to the sponsor

2 CFR 200.430(g)(4) (opens in a new tab)(4)) says it plainly: salaries used to meet cost sharing "must be supported in the same manner as salaries and wages claimed for reimbursement from Federal awards." For example, if a PI commits to 5% cost-shared effort on a hypothetical $1.2 million NSF grant and their IBS is $200,000, that's $10,000 per year in cost sharing. If the PI certifies only 3% effort, you've got a shortfall that needs to be made up elsewhere or reported to the sponsor.

Organizations frequently get into trouble by committing to cost-shared effort during proposal stage and then failing to track it post-award. Your effort reporting system needs to flag cost-sharing commitments and verify they're being met each reporting period. For more on managing these requirements, see our guides on federal grant compliance requirements and cost sharing and matching rules.

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Time and Effort Reporting Audit Findings for Federal Grants (and How to Avoid Them)

Auditors wrote up 1,648 payroll findings citing 2 CFR 200.430 or time-and-effort documentation in Single Audits for fiscal years 2022 through 2024, according to Grantsights analysis of Federal Audit Clearinghouse (opens in a new tab) finding text. They came from 1,082 different organizations, including school districts, cities, housing authorities, community action agencies and small nonprofits. We searched every finding text for those audit years through the FAC public API (opens in a new tab) on October 18, 2026, kept findings that mention "200.430" or "time and effort" along with payroll, salaries, wages, employees or personnel, and then flagged findings whose condition, cause or context sections (not the quoted rule) describe charges based on budgets, estimates or preset percentages. A hand check of 25 randomly drawn budget-flagged findings found 24 on point.

Read these numbers for what they are. A findings count measures what auditors reported, not how often the problem happens: only organizations spending $1,000,000 or more in federal awards in a year (the threshold in 2 CFR 200.501 (opens in a new tab) for fiscal years starting on or after October 1, 2024) need a Single Audit, auditors test only major programs, and late filers can still add to 2024. The text match also misses findings that describe the problem without either phrase, so treat 1,648 as a floor.

Here are the findings that come up again and again, with FAC examples for the first three:

1. Missing or Late Certifications

The finding: Effort certifications weren't completed, were completed months after the reporting period ended, or were signed by someone who didn't have firsthand knowledge of the work.

Real-world example: Kalama School District in Washington didn't get time-and-effort documentation for four employees whose $266,236 in salary and benefits went to an Education Stabilization Fund program; the cause, per the auditor, was that district officials didn't know the requirement applied (finding 2024-001, FAC report 2024-08-GSAFAC-0000356643 (opens in a new tab)). Aberdeen School District No. 5 had staff turnover, missed documentation for $696,887 in special education payroll, and had staff sign semiannual certifications after the fiscal year closed (finding 2023-001, FAC report 2023-08-GSAFAC-0000039439 (opens in a new tab)). Both districts later produced support, so the auditor didn't question the costs, but both findings were rated material weaknesses.

How to avoid it: Set a hard deadline for certification in your policy (for example, 30 to 60 days after each reporting period ends). Send automated reminders. Escalate non-responses to department leadership. Track completion rates and report them to senior administration.

2. Certifications That Don't Match Payroll

The finding: An employee certified 30% effort on a grant, but payroll records show 45% of their salary was charged to that grant, and no cost transfer was processed.

Real-world example: At Community Development Project, Inc. in New York, actual hours on approved time and effort reports didn't agree with the amounts billed to an Emergency Rental Assistance award for 56 of 60 samples tested, and the auditor rated it a material weakness (finding 2022-002, FAC report 2022-06-GSAFAC-0000034946 (opens in a new tab)). The timesheets existed. Nobody reconciled them to the reimbursement requests.

How to avoid it: Build a reconciliation step into your certification process. When a certification is submitted, compare it against payroll charges for the same period. Flag any variance above the threshold your written policy sets and initiate a cost transfer before closing out the period.

3. Charges Based on Budget Rather Than Actual Activity

The finding: The organization charged salaries to grants based on budgeted amounts and never verified that actual effort matched. This directly violates 2 CFR 200.430(g)(1)(vii), which states that budget estimates alone do not qualify as support.

Grantsights counted 269 FAC findings of this kind from 2022 to 2024, rising each year from 68 to 109. Three real cases show how it happens:

• American Institute For Foreign Study Foundation, Inc. in Connecticut charged a State Department exchange award "based on the budgeted payroll expenses," and the auditor recorded the cause as management believing it should charge based on budget (finding 2022-001, a material weakness with a modified opinion, FAC report 2022-12-CENSUS-0000237757 (opens in a new tab)).
• My Sister's Place, Inc. in Washington, DC charged payroll to a family violence program using a set budget percentage; management didn't know a true-up to actual time was eventually required (finding 2024-002, FAC report 2024-09-GSAFAC-0000367946 (opens in a new tab)).
• Sawyer County Housing Authority in Wisconsin set allocations for four employees at the start of the year and never adjusted them; management assumed steady weekly hours made records unnecessary. It's a repeat finding (finding 2024-003, FAC report 2024-12-GSAFAC-0000376086 (opens in a new tab)).

How to avoid it: This is the entire point of effort certification. The budget is your starting estimate. The certification is your after-the-fact confirmation. If you're only doing the budget part, you don't have a compliant system.

4. Effort Exceeding 100%

The finding: An employee's combined effort across all sources exceeded 100%, which is mathematically impossible under the regulatory framework.

How to avoid it: Build a 100% check into your system. Before a certification is accepted, validate that all activities for that employee sum to exactly 100% for the reporting period.

5. No Documentation of Cost-Shared Effort

The finding: The organization committed to cost-shared effort in the grant budget but didn't include it on effort certifications or track it in any system.

How to avoid it: Include all committed cost sharing on effort certifications. Build cost-sharing tracking into your post-award monitoring process. Review cost-sharing commitments quarterly against actual certifications.

6. Inadequate Internal Controls

The finding: The organization had no documented policies for effort reporting, no training program, and no monitoring to ensure compliance.

How to avoid it: Write a policy. Train everyone who certifies effort at least once per year. Monitor completion rates and certification accuracy. Document all of this. If you need help building out your compliance framework, see our guide on cost allocation plans for grants, which covers the broader cost documentation framework.

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Electronic Effort Reporting Systems

Paper-based effort reporting is dying, and for good reason. Electronic systems offer real advantages:

• Automated pre-population of payroll data so certifiers review actual charges rather than starting from a blank form
• Built-in 100% checks that prevent mathematically impossible certifications
• Automated reminders that improve completion rates
• Audit trails showing when certifications were completed, by whom, and any changes made
• Integration with payroll to trigger cost transfers when certifications don't match charges
• Reporting dashboards that let compliance officers monitor completion rates and flag problems

Commercial effort-certification products, such as Huron's ecrt, serve universities with many awards. Get a written quote: pricing depends on size and setup, and Grantsights didn't find published prices to cite.

A system only helps if its output drives the salary charges. Converge, Inc. in Mississippi had a time tracking tool but didn't use its reports to allocate salaries to its federal awards (finding 2022-005, FAC report 2022-12-CENSUS-0000259114 (opens in a new tab)). The Atlanta Botanical Garden tracked wages to avoid over-allocating against grant budgets, but the auditor found no process for allocating wages from submitted time records, in every payroll transaction tested (finding 2023-001, a material weakness, FAC report 2023-12-GSAFAC-0000056925 (opens in a new tab)). Write down who reconciles time to payroll, how often, and who approves the transfer before you buy anything.

For smaller organizations that can't justify a dedicated system, spreadsheet-based solutions work if you build in the right controls: mandatory fields, percentage validation, electronic signatures, and version control. The system doesn't have to be expensive. It has to meet the nine standards in 200.430(g)(1).

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Building a Compliant System: Step by Step

If you're starting from scratch or rebuilding a system that's been flagged by auditors, here's the sequence:

Step 1: Write Your Policy

Document your effort reporting methodology, including:

• Who must certify (all employees charged to federal awards, plus those with committed cost sharing)
• Certification frequency (quarterly or semi-annually)
• Deadline for completion (for example, 45 to 60 days after period end)
• Who can certify (the employee or a responsible official with firsthand knowledge)
• How cost transfers are initiated and approved
• Consequences for non-compliance

Step 2: Define Your Reporting Periods

Align with your payroll calendar. Common options:

Most organizations land on quarterly or semester-based periods. Monthly is more work than the accuracy improvement usually justifies.

Step 3: Set Up Payroll Integration

Your payroll system needs to distribute salary charges across funding sources based on budgeted percentages. At the end of each reporting period, pull a report showing how each employee's salary was distributed. This becomes the basis for the effort certification.

Step 4: Train Everyone

Every person who certifies effort needs to understand:

• What effort means (percentage of total activity, not hours)
• The 100% rule
• How to review pre-populated payroll data and flag inaccuracies
• Why certification matters (it's not just paperwork, it controls how much money gets charged to federal awards)
• The timeline for completion

Step 5: Monitor and Enforce

Track certification completion rates by department. Follow up on delinquent certifications within two weeks of the deadline. Run reconciliation reports comparing certifications to payroll charges. Report compliance metrics to institutional leadership quarterly.

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Special Situations

Summer Salary for 9-Month Faculty

Faculty on 9-month appointments who receive summer salary from federal grants require special attention. Summer effort is typically reported separately from academic-year effort. The summer salary rate should be calculated as the IBS divided by the academic period, then multiplied by the summer effort percentage. NIH's salary cap applies to the combined academic and summer salary.

Employees Who Switch Grants Mid-Period

If an employee stops working on one grant and starts on another in the middle of a reporting period, the certification should reflect the split. For example, if the period is January through March and the employee switched from Grant A to Grant B on February 15, the certification might show 50% Grant A effort and 50% Grant B effort for that quarter, even though the actual pattern was 100%/0% in January and 0%/100% in March.

Volunteers and Unpaid Effort

Volunteer time can count as cost sharing if it meets the requirements of 2 CFR 200.306, but it must be documented at rates consistent with those paid for similar work in the organization or labor market. You can't value volunteer time at whatever rate makes your cost-sharing commitment work.

Administrative and Clerical Staff

Under the Uniform Guidance, administrative and clerical salaries are normally treated as indirect costs. They can be charged directly to federal awards only when the work is integral to the project, the individuals can be specifically identified with the project, the costs are explicitly included in the budget, and the costs are not also recovered as indirect. If you're direct-charging admin staff, their effort needs to be certified just like any other employee on the award.

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What Auditors Actually Look For

During a Single Audit or OIG review, auditors examining effort reporting typically:

1. Select a sample of employees charged to federal awards and request their effort certifications for the audit period
2. Compare certified effort to payroll charges and calculate the dollar impact of any variances
3. Review cost transfers for timeliness, frequency, and adequacy of justification
4. Test the 100% rule across all sampled employees
5. Evaluate the internal control environment, including policies, training records, completion rates, and monitoring activities
6. Check cost-sharing documentation against grant commitments
7. Interview certifiers to verify they understood what they were signing

The dollar amounts at risk are substantial. If an auditor finds that effort certifications are unreliable for a sample of employees, they may project the error across the entire population of salary charges. As a hypothetical, at a university charging $50 million a year in salary to federal awards, a projected 5% error rate would put $2.5 million at issue.

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The Effort Reporting Failures That Actually Produce Findings

The FAC examples above share two causes, and neither is a software gap: documentation nobody collected because the people responsible didn't know the rule or had left, and allocations set at the start of the year and never trued up to actual work. Kalama's officials didn't know the requirement applied; Aberdeen lost the staff who ran the process; the Sawyer County housing authority and the Washington, DC family violence provider set percentages and left them. Neither problem is visible in the regulatory text of 2 CFR 200.430, and both show up in all three audit years Grantsights counted.

The specific cruelty of effort reporting: you can lose real money over a paperwork system failure even when the underlying work is legitimate.

Effort certification runs on everything from commercial software to spreadsheets. The software matters less than the policy: Converge and The Atlanta Botanical Garden had tracking tools and still drew findings. What matters more is a written escalation path for late certifiers, a named backup when the person running the process leaves, and a scheduled true-up of every budget-based allocation.

The honest friction is that after-the-fact effort certification, which replaced the old monthly effort report system at many universities, requires certifiers to accurately recall their time allocation months after the period ended. A certifier can sign a statement attesting to 30% effort on a grant while their calendar shows a sabbatical for half of that period. The certifier isn't lying intentionally: they just can't remember. Your system needs to prompt certifiers with payroll data and calendar information at the time of certification, not expect them to reconstruct it from memory.

If your certification completion rates are stuck, look at who receives the reminders. A PI focused on research can ignore an email from the grants office; a department chair or executive director who answers for the audit usually can't. Send escalations to the person with the authority to move the number, and say so in your policy.

What 2 CFR 200.430 and Agency Guidance Don't Tell You

The regulatory text gives you the nine standards in 2 CFR 200.430(g)(1). Agency policy statements add program-specific rules. But neither source prepares you for the practical realities of running an effort reporting system.

A strong average doesn't protect a weak department. You might have 95% certification completion overall, but if one department is at 60%, an auditor's sample can land there. Monitor completion rates at the department level and intervene early with units that are falling behind.

The rule doesn't give you a variance threshold, so your policy has to. 2 CFR 200.430(g)(1)(vii)(B) leaves "significant changes" in work activity to "the recipient's or subrecipient's written policies" and excuses short-term swings of one or two months. If your policy never defines significant, you can't show an auditor why you did or didn't adjust. Pick a number, write it down, and apply it the same way every period.

The 90-day cost transfer clock is an NIH rule, not a 2 CFR rule. 2 CFR 200.430 doesn't set a deadline for cost transfers. The NIH Grants Policy Statement section 7.5 (opens in a new tab) does: 90 days from when the error was discovered, with a full explanation and an official's certification. Check each sponsor's terms, and set your own deadline for the rest.

Audit reports still cite both paragraph numbers. The documentation standards moved from 200.430(i) to 200.430(g) in the 2024 revision. Grantsights counted FAC findings by citation: in audit year 2024, 126 payroll findings still cited 200.430(i) and 81 cited 200.430(g). Older awards can still fall under the earlier text, so check which version your award incorporates before you rewrite policy from someone else's finding.

Your effort certification training is audit evidence. Keep sign-in sheets, training materials, and dates. When an auditor interviews a certifier and they can't explain what they signed, the first thing the auditor checks is whether your organization provided training. Documented training protects you even when individual certifiers fall short.

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The Bottom Line

Time and effort reporting isn't glamorous, but it protects more grant dollars than almost any other compliance activity. Get the system right, train your people, enforce deadlines, and reconcile certifications against payroll every period. Every FAC finding named in this guide traces back to one of those steps being skipped, and the New York Medical College review shows how large the bill can get when estimates stand in for actual effort.

Start with your policy. If you're still lining up the awards that policy will cover, search open federal grants and check each program's terms for its own effort and cost-transfer rules. For the wider rule set, see our 2 CFR 200 Uniform Guidance guide and Single Audit requirements guide. Build (or buy) a system that meets the nine standards in 2 CFR 200.430(g)(1). Train everyone. Monitor everything. That's the entire playbook.

Related Guides

• 2 CFR 200 Uniform Guidance
• Grant Cost Sharing and Matching Requirements: Rules, Valuation, and Common Pitfalls for 2026

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Sources

• 2 CFR 200.430 (eCFR) (opens in a new tab)
• 2 CFR 200.306 (eCFR) (opens in a new tab)
• HHS OIG report A-04-20-03583: New York Medical College claimed unallowable grant costs (May 2024) (opens in a new tab)
• 29 CFR part 516: records employers keep under the Fair Labor Standards Act (eCFR) (opens in a new tab)
• 2 CFR 200.501: audit requirements (eCFR) (opens in a new tab)
• Federal Audit Clearinghouse data and API (GSA) (opens in a new tab): findings and findings_text for audit years 2022 to 2024, queried October 18, 2026
• NIH notice NOT-OD-26-034: Executive Level II salary limitation for 2026 (opens in a new tab) and NOT-OD-26-038: corrected effective date (opens in a new tab)
• NIH Grants Policy Statement 7.5: cost transfers (opens in a new tab)