GRANTS MANAGEMENT DIVISION

Financial Assistance Reference Guide

Essential tips for your NIST award

VERSION 3.0

1/24/2022
Welcome to the NIST Financial Assistance Community!

i

Congratulations on your new grant or cooperative agreement from the National Institute of Standards and

Technology (NIST). This Reference Guide is designed to provide you with the essential elements and answers to 

the most commonly asked questions of NIST financial assistance recipients (referred to as non-Federal entities 

throughout this guide). This document contains carefully selected topics designed to assist you from acceptance of

your award to close-out after it is completed.

The information in this packet is a summary of the numerous regulations and policies affecting your award and is

intended to provide guidance, including specific information regarding NIST’s implementation of various topics

found herein; it is not a replacement for the terms and conditions governing your award. Any conflicts or

inconsistencies between the information provided in this guide and the terms and conditions of an award will be

resolved in favor of the award terms and conditions. In addition to always reviewing the terms and conditions in your

award, including any Specific Award Conditions, you should always go back to the original text of the regulations 

that apply for further information or clarification. Unless otherwise specified in your award, all awards are required to

follow 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal

Awards.

Your Grants Specialist and Federal Program Officer are here to help you and your project reach your goals. Your

contact person for questions related to award terms and conditions is your Grants Specialist, while your Federal

Program Officer will assist with programmatic matters. Contact information may be found on page 2 of your award

agreement, form CD-450, as well as in the Specific Award Conditions incorporated in the agreement.

We are excited about your project and want to ensure that it is successful. When in doubt about how to proceed

with any component of your grant or cooperative agreement, reach out to your NIST grants team! We look forward

to working with you throughout the duration of your award.

Again, welcome to the NIST financial assistance community!

Regards,

Jannet Cancino

Division Chief
Table of Contents

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Roles and Responsibilities ...........................................................................................................................................................1

Getting Started: Accepting and Setting Up a New Award.............................................................................................................2

Monitoring, Compliance & Mandatory Reporting..........................................................................................................................3

Unfunded Grant Actions Mailbox (UGAM) ...................................................................................................................................4

Payments .....................................................................................................................................................................................5

ASAP for Payments .................................................................................................................................................................5

ASAP Enrollment Process .......................................................................................................................................................6

Non-ASAP Reimbursement of Funds ......................................................................................................................................6

Financial and Progress Reports ...................................................................................................................................................7

Identifying Prior Approval Requirements......................................................................................................................................8

Change in Scope .....................................................................................................................................................................9

Non-Federal Entity Personnel............................................................................................................................................... 10

No Cost Extensions .............................................................................................................................................................. 11

Budget Changes and Transfer of Funds Among Categories ................................................................................................ 12

Cost Principles...................................................................................................................................................................... 14

Indirect Cost Rates.................................................................................................................................................................... 15

Audits ........................................................................................................................................................................................ 17

Award “Close Out” .......................................................................................................................................................18

Remedies for Non-Compliance ................................................................................................................................................. 19

Additional Resources and Links ................................................................................................................................................ 20

Glossary .................................................................................................................................................................................... 21
Roles and Responsibilities

Grants Officer (GO)

The GO is the NIST official whose name appears on the Award Agreement (CD-450) and

is the official responsible for overseeing the business management and administrative

aspects of grants and cooperative agreements. These activities include, but are not

limited to, approving awards and amendments that obligate or de-obligate funds, approve

scope changes, suspend or terminate individual awards, and evaluating grant

applications for compliance with statutes, regulations and guidelines.

Grants Specialist (GS)

The GS the individual assigned responsibility for the day-to-day management of a

portfolio of NIST grants. The GS is the primary point of contact for the non-Federal entity

when dealing with award administration-related issues. The GS is responsible for financial

oversight, ensuring compliance with the terms and conditions of the award through

monitoring and routine assessment of the award, processing amendments and similar

administrative actions.

Federal Project Officer (FPO)

The FPO is the NIST official responsible for the programmatic, scientific, and/or technical

aspect of assigned applications and grants/cooperative agreements. The FPO

responsibilities include, but are not limited to, developing programs to meet the NIST

mission; providing programmatic technical assistance, post-award monitoring of project/program performance, including review of progress

reports and making site visits.

Non-Federal Entity (NFE)

Non-Federal entity means a state, local government, Indian tribe, institution of higher education (IHE), or nonprofit organization that carries

out a Federal award as a recipient or sub-recipient. For purposes of this guide, the definition of non-Federal entity is expanded to include

for-profit and foreign organizations unless explicitly stated otherwise. As defined in 2 CFR Part 200, a recipient is an entity that receives

funding directly from a Federal awarding agency to carry out an activity under a Federal program. A sub-recipient receives a sub-award

from a pass-through entity to carry out part of Federal Program. See 2 CFR §200.1 for more detail.

Non-Federal Entity Authorized Organizational Representative (AOR)

The AOR is the designated representative of the non-Federal entity with authority to act on the organization’s behalf in matters related to

the award and administration of grants and cooperative agreements. In signing the award agreement (CD-450) and any amendments (CD451), this individual agrees that the organization will assume the obligations imposed by applicable Federal statutes and regulations and

other terms and conditions of the award, including applicable assurances. These responsibilities include accountability both for the

appropriate use of funds awarded and the performance of the grant-supported project of activities as specified in the approved application.

Principal Investigator/Program or Project Director (PI/PD)

The PI/PD is the individual designated by the non-Federal entity, responsible for the scientific, technical, or programmatic aspects of the

award and for day-to-day management of the project or program. The PI/PD is a member of the non-Federal entity team responsible for

ensuring compliance with the financial and administrative aspect of the award. This individual works closely with designated officials within

the non-Federal entity to create and maintain necessary documentation, including both technical and administrative reports; prepare

justifications; appropriately acknowledge Federal support in publications, news programs, and other media; and ensure compliance with

other Federal and organizational requirements.

Key Personnel

Key personnel include roles such as the Project Director, Principal Investigator, or other designated personnel named in the award as

chiefly responsible for programmatic activities conducted under the award. NIST reserves the right to identify individuals as key personnel.

How do I identify my NIST 

“grant team”?

NIST personnel are identified in the 

Specific Award Conditions.

Additionally:

Grants Officer (GO)

The GO is the NIST official who

signed the CD-450, Award

Agreement.

Grants Specialist (GS)

The GS is identified, with complete

contact information in the Specific 

Award Condition NIST Award 

Contact Information.

Federal Program Officer (FPO)

The FPO is identified, with 

complete contact information, in the 

Specific Award Condition NIST 
Getting Started: Accepting and Setting Up a New Award

2

Upon receipt of your CD-450 Award Agreement, the following steps will help you get started in accepting and setting up your new NIST

award.

Accepting the Award

The AOR is responsible for reviewing and accepting the award. The AOR should

always review the entire grant agreement, including the applicable terms and

conditions and any Specific Award Conditions that have been included in the award

agreement. The full text of any referenced regulation or term must always be

reviewed to ensure the NFE fully understands the applicable authorities.

Identify and Setup for Payment/Reimbursement

Most NFEs are eligible to use the Department of Treasury’s Automated 

Standard Application for Payment (ASAP) system to electronically “drawdown” Federal award funds, on an as needed basis, to cover allowable grant

related expenses. NFEs must register in ASAP prior to initiating a request for 

funds; therefore, you are encouraged to register as soon as possible if you do 

not have an active ASAP account. If the NFE is ineligible to use ASAP (e.g.,

due to U.S. banking regulations),or the award contains a Specific Award

Condition limiting the use of ASAP, the NFE must utilize the Request for 

Advance or Reimbursement Form, SF-270, which requires advanced setup of 

Automated Clearing House (ACH) banking information with NIST. For more 

detailed information on how to identify the proper payment method and 

complete registration, review the Payments page.

Identify Financial and Progress Report Due Dates

Most awards issued by NIST require semi-annual progress and financial reporting in accordance with the DOC Financial Assistance

Standard Terms & Conditions. However, certain awards require quarterly reporting or unique intervals of reporting. The award agreement

will include a Specific Award Condition specifying both report frequency and schedule. Unless otherwise received in writing from the 

Grants Officer, reports are due, regardless of activities completed, dollars spent, or time elapsed since award (or lack thereof). Failure to 

comply with reporting requirements may have adverse impacts to your current and future funding from NIST. Refer to the section on 

Progress andFinancial and Progress Reports for more information.

The CD-450 award agreement must be signed and returned within

30 business days from the date the grant award agreement packet is 

received; after 30 days the GO may unilaterally terminate the award.

The signed agreement must be returned via email.

What are the terms, regulations and

conditions guiding my award?

The combination of the following elements

provides the framework which your award must

follow. It is imperative as a recipient receiving

financial assistance from NIST that you review

and understand these elements.

Federal Regulations (Uniform Guidance)

2 CFR Part 200 Uniform Administrative

Requirements, Cost Principles, and Audit

Requirements

Award Terms and Conditions, as identified in

your award:

Department of Commerce Financial Assistance

Standard Terms & Conditions; and,

Federal-wide Research Terms & Conditions, if

incorporated

Specific Award Conditions

Elements related specifically to your new award

contained within your award agreement.
Monitoring, Compliance & Mandatory Reporting

3

Identifying and Reporting Conflict of Interest

In accordance with 2 CFR §200.112, NIST requires each NFE to maintain an appropriate written and enforceable policy regarding Conflict 

of Interest, and to disclose in writing any potential conflict of interest to NIST or the pass-through entity as defined in 2 CFR §200.1, Further,

in accordance with the DOC Financial Assistance Standard Terms & Conditions, the non-Federal entity must maintain written standards of 

conduct to establish safeguards to prohibit an Interested Party from using their positions for a purpose that constitutes or presents the 

appearance of personal or organizational conflict of interest, or personal gain in the administration of an award. If, at any time throughout

your award, you believe you have a potential conflict of interest or have any questions regarding identifying or reporting of a conflict of

interest, contact your Grants Specialist immediately.

Mandatory Disclosures

The NFE or applicant for a Federal award must disclose, in writing to NIST, or a pass-through entity, all violations of Federal criminal law 

involving fraud, bribery, or gratuity violations potentially affecting the Federal award (2 CFR §200.113). In addition, if you receive federal 

awards (currently active grants, cooperative agreements, and procurement contracts), greater than $10,000,000 for any period of time 

during the period of performance of an award/project, you are required to maintain the currency of information disclosed in the System for

Award Management, SAM.gov, (and made available in the Federal Awardee Performance and Integrity Information System (FAPIIS)) any

information about criminal, civil, and administrative proceedings, and/or affirm that there is no new information to

provide. For further information about this requirement refer to 2 CFR 200 Appendix XII.

Procurement Requirements

The Uniform Guidance requires all non-Federal entities to maintain procurement policies and standards in their procurements made under

a Federally funded assistance agreement. In general, non-Federal entities must award procurement contracts in accordance with their

documented procurement procedures and provide documentation, upon request by the awarding agency, that substantiates their

procurement process is consistent with the requirement set forth in 2 CFR §200.317-327. Further, the Uniform Guidance stipulates specific

procurement standards and requirements for purchases based on procurement type and dollar value. The Special Award Conditions will

further stipulate any additional procurement requirements or limitations (e.g. compliance with Buy American standards).

Sub-Recipient Risk Assessment & Monitoring

As a non-Federal entity, or pass-through entity, you must require all subrecipients, including lower tier sub-recipients, under the award to comply

with the terms & conditions of the award, including applicable provisions

of the Uniform Guidance that flow down to the sub-recipient. This

process includes a risk assessment, an evaluation of the sub-recipient’s

risk of noncompliance with Federal statutes, regulations, and the terms

and conditions of the sub-award. Consideration of these risk factors will

assist in the determination of appropriate methods for monitoring. Your

risk-based assessment will result in utilization of appropriate monitoring

tools such as reports, on-site visits, audits, and technical assistance, to

ensure performance goals are met. See 2 CFR § 200.331-333 for 

additional requirements of sub-recipient monitoring.

NIST Project Monitoring & Site Visits

NIST Project monitoring is the joint responsibility of the

Grants Office, Federal Program Office, and non-Federal

entity. NIST personnel will actively monitor the status

and progress of each grant or cooperative agreement.

Monitoring may include phone discussions, e-mails,

meetings and events, reviewing of progress and financial

reports, conducting site visits, or any other form of

communication deemed appropriate by the Grants

Officer or Federal Program Officer to track your

progress. The purpose of monitoring is to ensure the

terms and conditions of awards are fulfilled, and that

Federal funds are managed appropriately to achieve

project outcomes. Site visits and other monitoring

activities will also assist the non-Federal entity to identify

current or potential problems and help in resolving

issues.
Unfunded Grant Actions Mailbox (UGAM)

4

What is UGAM?

The UGAM Mailbox was implemented as a mechanism to expedite the execution of certain unfunded actions. UGAM is an email box that 

allows for improved internal tracking and quicker processing times for these common award action requests. The address for UGAM is 

ugam@nist.gov.

Actions to be submitted to UGAM

Requests for unfunded award actions, which include, but are not limited

to:

• Requests for no-cost extensions

• Changes in key-personnel

• Changes in scope

• Budget revisions (no additional funds requested)

• Novation

• Name change

• Award transfer

Submitting requests to UGAM

Unfunded award action requests and related correspondence, including justification to support the request, sent to the mailbox,

must contain the following information in the email subject line:

(1) Recipient name, (2) NIST award number, (3) Principal Investigator/Project Director, and (4) Action being requested (e.g., no 

cost extension, change in key personnel, etc.).

Unfunded award action requests shall not be sent directly to NIST personnel (e.g., Grants Specialist, Grants Officer, Administrative

Assistant, GMD Division Chief, Federal Program Officer, etc.), unless the Specific Award Condition specifies otherwise. Any requests 

sent directly to NIST personnel will be returned to the sender with instructions on how to submit through the ugam@nist.gov mailbox.

Do not submit the following to UGAM

General correspondence, documents or requests related to closeout, including extension to the closeout period, or funded amendment

requests must not be submitted to UGAM. These inquiries are outside the scope of UGAM and will be returned to the sender unprocessed.

The mailbox shall not be used for any other purpose except as identified above or in the Specific Award Conditions.

Unfunded Grant Actions

Mailbox ugam@nist.gov
5

The entire ASAP enrollment process takes between 2 –

4 weeks, so it is very important to complete the process 

as specified in the ASAP enrollment notifications. Do 

not wait until you need grantfunds to initiate account 

setup.

Payments

All Payments must be issued in accordance with 2 CFR §200.305 and DOC Financial Assistance Standard Terms and Conditions, Section

B.02. Unless otherwise specified in the Specific Award Conditions, payments for NIST awards are made through ASAP. Only specific 

entities or awards as outlined herein may utilize theSF-270, Request for Advance or Reimbursement of Funds. ASAP eliminates the need 

for hard-copy invoice submission and allows non- Federal entities to electronically “draw-down” grant funds, as needed, to cover allowable 

expenses through direct transfer to a U.S. bank account. 

Users must have a U.S. bank account to access ASAP. As a result of recent changes in U.S. banking regulations, many foreign organizations

may not be eligible to use this system. If your organization is prohibited from utilizing ASAP, or your award contains a Specific Award

Condition with alternate payment instructions, you must submit reimbursement forms (SF-270) and ACH payment information. See the

following page for instructions on requesting payment outside of ASAP.

ASAP for Payments

Enrolling in ASAP

The Federal agency has the responsibility for enrolling your

organization into ASAP. To initiate the ASAP enrollment

process, the non-Federal entity needs to provide to the Grants

Specialist the ASAP Point of Contact (see chart below) foryour 

organization, including name, email address, mailing address, 

telephone number, and the organizational EIN and DUNS® 

numbers. The ASAP enrollment is a multi-step online process.

The remaining steps are completed by the nonFederal entity within the ASAP system (e.g., adding all required

personnel and bank account information in an ASAP account). Once the non-Federal entity enrollment is initiated, the Point of Contact

must contact the ASAP Customer Support Team (contact information below) to create a profile in ASAP.

ASAP User Roles (as identified by ASAP)

POINT OF CONTACT (POC) is responsible for adding, modifying, and deleting the non-Federal entity officials in ASAP. This

person’s contact information must be sent to the Grants Specialist when initiating enrollment.

HEAD OF ORGANIZATION (HOO) is the non-Federal entity management official who approves or rejects the officials named

by the Point of Contact. The HOO can add officials but not delete officials. Only one person shall be designated as the Head of

Organization.

RE-DELEGATED HEAD OF ORGANIZATION (RHOO) can act on behalf of the Head of Organization to approve officials.

AUTHORIZING OFFICIAL (AO) confirms the non-Federal entity’s information and identifies users (e.g., payment requestor)

who need access to ASAP. This role is not synonymous with, and must not be confused with, the Authorized Organizational

Representative identified in the award agreement.

FINANCIAL OFFICIAL (FO) enters the bank account information for the non-Federal entity.

PAYMENT REQUESTOR (PR) may request funds from the non-Federal entity’s ASAP account.
6

ASAP Enrollment Process

There are a series of steps to assign designated personnel for each role and financial institution information. Enrollment steps

must be completed within 30 days from when initiated or the enrollment process will be terminated. Each person identified will

receive their own unique user ID and password from the Department of Treasury.

1. The Point of Contact must login to ASAP and complete the following: 1) accept the role as ASAP Point of Contact; 2) verify all

organizational information entered by NIST, and 3) add personnel for the Head of Organization, Authorizing Official, and Financial Official

roles. Individuals may be assigned to more than one role.

2. The Head of Organization must subsequently login to ASAP and approve the Authorizing Official and Financial Official added by the

Point of Contact.

3. The Authorizing Official must then login and complete the non-Federal entity’s basic information in the organization’s profile and add

the Payment Requestor(s). At least one Payment Requestor is required for ASAP.

4. The Financial Official must login and add the bank account information for the entity. This must be a U.S. Bank account.

5. The U.S. Department of Treasury will then validate the account information (this may take up to 7 days). After validation, NIST will

finalize the ASAP enrollment.

Transferring funds using ASAP

The designated payment requestor(s) is the authorized individual with access to

ASAP to request Federal funds (draw-down) as needed to pay for allowable

grant costs. In accordance with DOC policy, funds drawn down in advance

through ASAP must kept in an interest-bearing account and be spent within 3

business days. It is rare that all funds will be drawn down at once. Funds drawn

down that are not spent timely must be returned to ASAP.

If your award contains Specific Award Conditions limiting your ability to draw

down funds in advance (e.g. reimbursement only), your award will outline the

necessary steps for requesting reimbursement through ASAP. As always, you

are encouraged to discuss any questions you have with your Grants Specialist.

Non-ASAP Reimbursement of Funds

How do foreign organizations and nonASAP using non-Federal entities request a

reimbursement?

When the Form SF-270 or successor form is used to request 

payment, the recipient must submit the request no more than 

monthly, and advances must be approved for periods to cover 

only expenses reasonably anticipated over the next 30 calendar 

days. 

The non-Federal entities must submit a completed ACH

Vendor/Miscellaneous Payment Enrollment Form, SF-3881, to

NIST as instructed in the Specific Award Condition. The nonFederalentity must immediately notify the Grants Specialist if this

information changes during the award period to prevent delay in

payment.

For each payment or reimbursement requested during the award

period, the non-Federal entity must submit a Request for Advance

or Reimbursement Form, SF-270, via email, directly to the Grants

Specialist. The Financial Representative or AOR must sign and 

submit the SF-270. Upon review and approval of the request,

funds will be transferredelectronically to the financial institution 

designated on the SF-3881.

Returning funds paid via SF-270/nonASAP users

The non-Federal entity must submit all refund checks 

for overpayments to the NIST Accounts Receivable

Office identified below and notify the assigned GS via 

email. All checks must identify the awarding agency 

(NIST),the award number, and no more than a twoword description toidentify the reason for the refund.

Submit to:

National Institute of Standards and

TechnologyAccounts Receivable

100 Bureau Drive, Stop 1624

Building 101, Room A813

Gaithersburg, MD 

20899-1624

For enrollment assistance and questions

contact the ASAP Customer Service

Center:

Bureau of the Fiscal Service

Kansas City FinancialCenter

Phone: (855) 868-0151

E-mail: asaphelpdesk@fiscal.treasury.gov

Hours of Operation: 6:30 AM - 5:30 PM Central Time

(Monday – Friday).

Listen to and follow the prompts for ASAP.
7

Financial and Progress Reports

There are reporting requirements associated with every NIST grant or cooperative agreement.

These reports are due at specific, pre-defined times during the life cycle of a grant. It is

important that all reports are accurate, complete, and submitted on time. Reports are required

even if no activity has occurred on the project or grant. Progress reports cover only activities

occurring during the subject reporting period, while financial reports are cumulative.

Financial and progress report schedule

For most NIST awards, the progress and financial reports are due on a semi-annual basis for

the periods of October 1 - March 31 and April 1 - September 30, or any portion thereof, unless

otherwise specified in a Specific Award Condition. Some programs might require quarterly

(October 1 – December 31, January 1 – March 31, April 1 – June 30, and July 1 – September

30), annual or off-period reporting. Interim Reports are due 30 days after the end of each

reporting period. Final reports are due 120 days after the end date of the award; refer to the

closeout section of this guide for additional detail on final report requirements.

Elements of the progress report

The Specific Award Conditions will indicate if a certain format for the progress report is required

(e.g., the Research Performance Progress Report). The progress report will generally include 

thefollowing elements. Discuss any specific requirements with your FPO, including formatting 

or additional submission requirements.

AWARD INFORMATION: Award Number, Project Title, Agency, Principal Investigator, Award

Period, and Reporting Period.

PROJECT SUMMARY: A summary of the activities in the approved award and corresponding

project description. The focus must be on activities to be completed within the reporting period.

PROGRESS AND OUTCOMES: Discussion of the activities and progress of the project that

occurred within the reporting period, including data, results of any monitoring or data collection

activities. To the greatest extent practicable, performance must be tied back to funds spent in the

progress report 2 CFR §200.329.

CHALLENGES: Any challenges encountered, anticipated problems, delays with the project, or

budget transfers, including explanation.

OTHER REQUIREMENTS: The Specific Award Conditions will stipulate other reporting

requirements, if applicable.

Federal Financial Report (SF-425)

The financial report must be submitted on the most current SF-425 form. Obligations and 

expenditures must be reported, per the required reporting schedule identified in the award. 

The report must match the data as reported in ASAP or as substantiated by the SF-270. The

Grants Specialist must reconcile spending against progress reported in the corresponding

progress report and monitor drawdowns and spend for unanticipated over or under-spend

during the life of the award.

What if I’m late submitting

my reports?

Non-compliance of reporting

requirements will be treated as

failure to comply with the terms

and conditions of the award.

Enforcement actions can begin 15 

business days after thedue date, if 

the report has not been received, 

or if late reports are an on-going 

problem. Ramifications may 

include withholding of funds

pending compliance, additional

oversight actions, or implications

for future awards with NIST.

Contact your Grants Specialist as

soon as possible if you are having

problems with the reporting

deadline. NIST utilizes an

automatic reminder system to help

prevent late reporting. Discuss all

challenges as soon as possible

with your Grants Specialist to keep

your award in good standing.

*How do I submit the

reports?

Progress and financial reports 

must be submitted, via email, to 

greports@nist.gov.

*Some programs may specify a

designated portal for submitting

reports; the award agreement

Specific Award Conditions provide

direction on any deviation from these

requirements (e.g., Manufacturing

Extension Partnership).

EXAMPLE: An award is effective August 1, has a 12-month period of performance, and a semiannual reporting requirement. The first reporting period will cover August 1 through September 30

and is due October 30 (30 days after the end of the reporting period). The second report will

include the period of October 1 through March 31 and is due April 30. The final report will cover

the period of April 1 through July 31 and will be due November 28 (120 days after the award end

date).
8

Identifying Prior Approval Requirements

Certain actions, while common over the life of a grant or cooperative agreement, require prior written approval from the Grants Officer. The

table below highlights several of the key differences in the DOC Financial Assistance Standard Terms and Conditions and the Federalwide Research Terms and Conditions as it relates to the requirement of prior approval; this is not an exhaustive list of Prior Approval

requirements for either set of terms and conditions. The DOC has waived certain prior approvals for those awards incorporating the

Federal-wide Research Terms and Conditions, as outlined below. For those awards only incorporating the DOC Standard Terms and

Conditions, actions requiring prior approval are further delineated in 2 CFR §200.308, Revision of budget and program plans and 2 CFR

§200.407, Prior Written Approval.

For all prior approval award action requests, that do not include additional funding, the non-Federal entity must submit the request, in

writing, to the UGAM, or as instructed in the Specific Award Conditions. A request for prior approval is not granted until approval is

received in writing from the Grants Officer. The Grants Officer must make the final determination of the vehicle required to authorize the

change (e.g. CD-451 Amendment or unfunded letter approval).

Each Award Agreement, CD-450, will specify all Terms and Conditions, including any award or program specific conditions or deviations,

that apply to the financial assistance award. As the non-Federal entity, it is your responsibility to ensure a full and complete understanding

of, and compliance with, the terms and conditions applicable to your NIST financial assistance award.

Award Action Request Prior Approval Required Reference

Page (this

guide)

Federal-wide

Research Terms &

Conditions

DOC Standard

Terms & Conditions

Change in Scope Yes Yes Page 9

Change of PI Yes Yes Page 10

No-Cost Extension (up to 12 months) No Yes Page 11

Additional Funding Yes Yes

Page 12 Budget Changes and Transfer of Funds Among 

Direct and Indirect Categories

No (Exception: Approval

required for reallocating

participant support costs)

Maybe

Costs Requiring Prior Approval in Cost Principles Yes (unless waived in

the award agreement) Yes Page 14

NOTE: Just because an action does not require prior approval, there may be reporting and

notification requirements. In addition to the guidance in this reference guide, always refer to the

Terms and Conditions, including any Specific Award Conditions, for additional information. If 

youare ever in doubt if an action requires prior approval, ask your Grants Specialist.

Federal-wide Research Terms & Conditions

Effective November 12, 2020, the Department of Commerce adopted the new set of Federal-wide Research Terms and

Conditions. All related information may be found on the National Science Foundation’s website, including links to the

previous set of Research Terms. Upon issuance of a funded amendment or renewal executed after November 12, 

2020, the Federal-wide set of research terms will be incorporated into existing research awards. Unless otherwise

specified in the award, no additional prior approvals are required; refer to the DOC approvals in the most recent Prior 

Approval Matrix for reference.
9

Change in Scope

Sometimes, the work being performed by the non-Federal entity as part of a

grant or cooperative agreement requires altering key elements that were part of

the original, approved scope of work. Although necessary, these changes are

often a Change in Scope and require amendment of the award and written

authorization by the Grants Officer (CD-451).

The non-Federal entity must report any programmatic changes, which often

include changes in scope, to NIST (2 CFR § 200.308). To ensure compliance,

the non-Federal entity is encouraged to always discuss potential or anticipated

changes with NIST prior to initiating a change. All approved changes, or minor

deviations (see Example 1 below) should be discussed in your progress reports.

Not all requests are guaranteed to be approved due to program requirements,

funding, regulation, and other restrictions.

This change will improve my project; it’s okay to just make the change, right?

No. Any changes in scope or major programmatic changes require a written request and approval for a change in scope. Changes must

not be implemented until the non-Federal entity receives approval (CD-451 Amendment) from NIST. The non-Federal entity must

repay any Federal funds expended relating to an unauthorized change in scope. Certain changes, or repetitive noncompliance, may result

in additional enforcement actions. Always discuss any modifications, no matter how minor, with your Grants Specialist in advance to

prevent an inadvertent change in scope.

Minimum Requirements of a Request for Change of Scope

A request for a change in scope must include a justification for the change, including a revised

project plan and budget narrative. Often a budget change is also required to either re-allocate

or move funds between direct line items. You are encouraged to submit as much supporting

documentation as necessary to substantiate the request.

Notice of approved change

The content and extent of the change will dictate the notification process. All changes in

scope must be issued via a CD-451 Amendment with the change(s) included. Typically,

one amendment will address all requested changes (e.g., programmatic, budget, etc.).

Requests for a change of scope must be reviewed just as thoroughly as the original

proposal. Therefore, approval may take considerable time and is never guaranteed.

Ask yourself:

Will this change modify the overall [goals]

[milestones] [objectives] [activities] of the project?

If the answer is YES, it requires a change in scope,

subject to concurrence and approval by NIST.

EXAMPLE 1: The original timeline had the date of the workshop in April the following year. Due to scheduling challenges and a late

winter storm, the workshop was changed to June. This change will not impact the other grant activities.

This is NOT a change in scope, but the change SHOULD be documented in the progress report. Minor modifications to 

the activity timeline, generally, will NOT trigger a change in scope.

EXAMPLE 2: Following the above example, you decide to change the content of that workshop from the latest nanofabrication

techniques to teaching marketing strategies for end designs.

This would be a major change in the activities and require a change in scope and written approval.

Submitting a change in scope

request

Requests must be submitted in writing, via

email, detailing the request. The request must 

be submitted to UGAM, or as identified in the 

Specific Award Conditions by either the AOR 

or the PI.
10

Non-Federal Entity Personnel

Change in Key Personnel and Principal Investigator/Project Director

In accordance with 2 CFR § 200.308 certain changes in key personnel or Principal Investigator (PI) require approval from the Grants

Officer. Recipients must discuss any changes with your NIST Grants Specialist and Federal Program Officer as soon as possible. In some

cases, the selection of an application for award is made partly on the qualifications of the Principal Investigator. NIST may wish to consider

alternative remedies (e.g., transferring the award to the current PI’s new organization, when applicable). A request to change the official PI

or Key Personnel must be submitted via email to the UGAM, or as designated in the Specific Award Conditions. The request for a change

in PI or Key Personnel is not approved until the Grants Officer issues written approval.
11

No Cost Extensions

NIST may authorize a one-time extension to the expiration date of the

award for up to 12 months if additional time beyond the established award

end date is required to assure adequate completion of the approved scope

of work. No additional funds shall be authorized as part of a no-cost

extension. Requests must be submitted at least 30 days prior to the

expiration of the award. For awards that incorporate the Federal-wide

Research Terms and Conditions, all no-cost extension requests, invoking

the “expanded authority” right, must be submitted at least 10 days prior to 

the award end date; see “What is ‘expanded authority?’” below for

instructions specific to this authority.

Requirements for a no cost extension request

For non-research awards, requests must include a letter or document outlining the need for a no-cost extension with the following required

information:

• NCE request signed by the Authorizing Official;

• A detailed explanation of why the project could not be completed by the approved end date;

• Description of the project activities that require support during the extension;

• Revised period of performance; and

• An OMB-Approved Budget Form (SF-424A or R&R budget form) and a detailed budget narrative by direct cost category for the 

remaining balance of funds to be carried over.

NOTE: A narrative of all remaining work to be completed should be submitted. This MUST NOT include any new work that was not included in the 

most currently approved scope of work. Any new work will be denied.

For research awards, the Research Terms and Conditions include the provision for NFEs to extend the final budget period of a previously approved 

project period, one time for a period of up to 12 months, without additional funds. This action must be taken before the project period ends, and 

NFEs are required to notify the Grants Office when they have exercised this authority at least ten (10) days before the end of the period of 

performance. The approval requirement for the first NCE request is waived; however, the NFE is required to notify the Grants Office in writing, and it 

must indicate the new period of performance. Any subsequent no-cost extension or extension of more than 12 months must be approved by the 

Grants Officer in writing, and it must be submitted to the Grants Office at least 30 days before the end of the period of performance.

Submitting a request for a no cost extension

The no cost extension request (or notification of extension if you

have expanded authority) must be submitted in writing by the

AOR via email to the UGAM,or as instructed in the Specific Award

Conditions.

This one-time extension shall not be exercised

merely for using unliquidated balances, or

perform new activities not already described in

the approved project narrative. Non-Federal

entities are not authorized to extend an award

that contains a zero balance.

What is “Expanded Authority”?

The NIST awards that support research are under the

provisions of the Federal-wide Research Terms and

Conditions. These awards may have expanded authority. The

expanded authority allows you to notify NIST you are extending

the award for up to 12 months. After timely notification, at least

10 days prior to the award end date, is received by the Grants

Office and a review for compliance is completed, an

amendment CD-451 will be issued to amend the award with the

new end date. The requirement for a non-Research no cost

extension request is not applicable to the notifications for

expanded authority. Not all awards have expanded authority. 

This authority shall only be used once.
12

Budget Changes and Transfer of Funds Among Categories

The Terms and Conditions incorporated into your award dictate the level of prior approval required for budget changes and transfers of

funds. Awards incorporating the Federal-wide Research Terms and Conditions have limited requirements for prior approval in regards to

budget changes; while awards without the Federal-wide Research Terms and Conditions are often required to obtain prior approval from

NIST for budget plan revisions, in accordance with 2 CFR § 200.308 and DOC Financial Assistance Standard Terms and Conditions

Section B04. Requests for prior approval must be reviewed by the Grants Officer who must make the final determination on such requests

and notify the non-Federal entity in writing. In all instances, a recipient must receive prior approval from the Grants Officer to create a new

budget category, regardless of the amount of the proposed transfer or inclusion of the Federal-wide Research Terms and Conditions.

Standard budget categories include personnel, fringe, equipment, supplies, sub-contracts, etc. All non-Federal entities are required to

report deviations from budget, project scope or objective in the next progress report.

Transfer of Funds within the approved budget categories

Awards of $250,000 or less and all awards incorporating the Federal-wide Research Terms and Conditions

In most cases, if the Federal share of the award is equal to or less than the simplified acquisition threshold (currently at $250,000), or 

generally an award of any value incorporating the Federal-wide Research Terms and Conditions, the non-Federal entity may transfer

funds between existing budget categories without Grants Officer approval.

Awards over $250,000, not incorporating the Federal-wide Research Terms and Conditions

If the Federal share of the award is greater than the simplified acquisition threshold, the non-Federal entity must receive approval, in

writing, from the Grants Officer unless the following applies:

• The requested transfer is between existing direct budget categories; and

• The aggregate of all transfers (previous and current request) is less than 10% of the total budget approved by the Grants Officer.

The total budget is the total Federal and non-Federal funds most recently approved by the Grants Officer.

EXAMPLE 1: The specialty supply item that you needed to build the monitoring device went up by $500 from when you received the

original quote included in your budget. This item was listed in the “supplies” category in your original approved budget. Fortunately,

you were able to arrange free lab space for another portion of your project, so the $500 you had in your approved budget for that

purpose under “other” will not be needed. Additionally, your award incorporates the Federal-wide Research Terms & Conditions. You

are allowed to move the funds from the “other” into the “supplies” to cover the increased cost of the item, without approval from NIST

because awards incorporating research terms and conditions do not require prior approval to move funds. However, this change must

be documented and discussed in your progress report.

EXAMPLE 2: The total Federal share of your award is $225,000, with a non-Federal match of $50,000, for a total award budget of

$275,000. You previously transferred an aggregate of $20,000 between direct cost categories. Now, a piece of specialty equipment

essential to the project must be replaced; the original piece of equipment was contemplated and approved as part of your original

proposal. The replacement equipment costs $10,000. You have realized significant cost savings in several other direct budget

categories due to unanticipated efficiencies in the project.

This example describes a Transfer of Funds which requires advanced, written authorization by the Grants Officer because 

1) the Federal share is in excess of $250,000, 2) the Federal-wide Research Terms and Conditions do not apply, and 3) the

$10,000 transfer now increases the cumulative amount of direct cost category budget transfers to $30,000 ($20,000 + 

$10,000), which is greater than 10% of the $275,000 ($27,500) approved budget.
13

Requirements for Budget Changes

The request must be submitted by the AOR to the UGAM, or as identified in the Specific Award Conditions. The request must include 

the following elements:

• Justification describing why the budget change is 

necessary and any programmatic implications

resulting from the change.

• A revised budget narrative. This may be included as

part of the justification.

• A revised SF-424A or R&R budget form (research and

related); the form must be consistent with your original

application. Fillable PDFs can be downloaded from

the Grants.gov website.

EXAMPLE: Adding a new milestone for testing to the project triggers a change in scope. This new milestone might require

shifting some costs to a new category that exceeds 10% of the entire budget.

This example describes a “Change of Scope and budget changes” since you are adding a new milestone that will trigger new

activities to your award. This is not a simple budget change and prior approval is required. Refer to the section “Change in Scope” of

this guide for more information.

What if my request is for a new activity

not included in the original award?

Any new activity not included in the original award would

need to be submitted and approved by the Grants Officer as

a “Change in Scope.” If the change in scope impacts the

approved budget, a request for budget changes must be

submitted and approved. These requests can be done in

one step by submitting a request in writing via email to the

UGAM, or other portal identified in the Specific Award

Conditions.
14

Cost Principles

Most financial assistance awards with NIST must adhere to the Federal Cost Principles outlined in 2CFR Part 200, Subpart E. . 48 CFR 

§ 31.2 only applies if specifically incorporated as part of the terms of the award; absent express incorporation, for-profit entities are 

subject to the Federal CostPrinciples set forth in Subpart E. It is the recipient’s responsibility to review and understand the applicable 

regulation(s) to ensure that all costsare allowable.

Allowable cost

An allowable cost is one that meets the criteria for authorized expenditures in the Federal

Cost Principles; principally, that it is necessary and reasonable for the performance of the

award and allocable to the award, and not otherwise specifically prohibited. Cost

Principles, Subpart E.

An allowable cost may also refer to only those categories of costs which have funding

included in the approved budget.

Allocable Costs

All costs must also be Allocable in accordance with 2 CFR § 200.405(a). A cost is

allocable to a particular Federal award or other cost objective if the goods or services

involved are chargeable or assignable to the Federal award or cost objective in

accordance with relative benefits received.

Reasonable

All costs must also be Reasonable. A cost is reasonable if it does not exceed that which

would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost (the Prudent

Person Test). 2 CFR § 200.404.

Prior Written Approval

2 CFR § 200.407 provides a list of those items for which prior written approval is required (e.g. travel, pre-award costs, entertainment). Prior

written approvals for awards incorporating the Federal-wide Research Terms and Conditions differs; refer to the DOC column in the Federalwide Research Terms & Conditions Prior Approval and Requirements Matrix* for those instances in which prior approval is required.

2 CFR § 200.407 “In order to avoid subsequent disallowance or dispute based on unreasonableness or nonallocability,

the non-Federal entity may seek the prior written approval of the cognizant agency for indirect costs or the Federal

awarding agency in advance of the incurrence of special or unusual costs. Prior written approval should include the

timeframe or scope of the agreement.”

ALL COSTS MUST BE

ALLOWABLE, ALLOCABLE, 

AND REASONABLE.

EXAMPLE: A staff person who is working on five different projects must be charging

their time between those five different projects, based on the percentage of time that

is spent on each project. If a staff member is working solely on one project, their full

salary may be charged to that award, if included in the approved budget.

What happens if a cost is

unallowable?

The non-Federal entity is required to maintain

documentation substantiating expenses. It is

the responsibility of the non-Federal entity to

ensure that all costs are allowable, allocable,

and reasonable, and that costs requiring prior

approval are so authorized. Payments made

for costs determined to be unallowable by

NIST must be refunded (including interest) to

the Federal government in accordance with

instructions from the NIST Grants Office. See 

guidance at 2 CFR § 200.410.
15

Indirect Cost Rates

The payment of Facilities and Administrative (F&A) costs are generally based upon rates

established through a formal agreement between the non-Federal entity and the cognizant

Federal agency. The negotiated rate is applied to the applicable direct cost base to determine

the amount of F&A costs to be awarded.

“Indirect (F&A) costs means those costs incurred for a common or joint purpose benefitting

more than one cost objective, and not readily assignable to the cost objectives specifically

benefitted, without effort disproportionate to the results achieved. To facilitate equitable

distribution of indirect expenses to the cost objectives served, it may be necessary to establish

a number of pools of indirect (F&A) costs. Indirect (F&A) cost pools must be distributed to

benefitted cost objectives on bases that will produce an equitable result in consideration of

relative benefits derived.” 2 CFR § 200.1 Indirect (F&A) Costs

The costs of operating and maintaining facilities, depreciation, and administrative salaries, are

examples of the types of costs that are usually treated as indirect costs.

There is no universal rule for classifying certain costs as either direct or indirect (F&A) under

every accounting system. A cost may be direct with respect to some specific service or

function, but indirect with respect to the Federal award or other final cost objective. It is

essential that each item of cost incurred for the same purpose be treated consistently in like

circumstances either as a direct or an indirect (F&A) cost to avoid possible double- charging of 

Federal awards (e.g. overhead costs directly related to personnel funded through aFederal 

award). Guidelines for determining direct and indirect (F&A) costs charge to Federal awards

are provided in the 2 CFR Part 200 Subpart E – Cost Principles.

Indirect Cost Rate Definitions

INDIRECT COST RATE: The ratio, expressed as a percentage, of an organization's total

indirect costs (numerator) to its direct cost base (denominator). The base can be defined as

salaries and wages, modified total direct costs, or some other financial number that provides

for an equitable distribution of indirect costs to the benefiting activities. When a rate is

established for a specific cost center, the rate represents the ratio of the total allowable

indirect costs allocated to the activity to the direct base costs of the activity.

INDIRECT COST PROPOSAL: Indirect cost rate proposal means the documentation

prepared by a non-Federal entity to substantiate its request for the establishment of an

indirect cost rate as described in 2 CFR Part 200, Appendix III —Indirect (F&A) Costs

Identification and Assignment, and Rate Determination for Institutions of Higher Education

(IHEs) through 2 CFR Part 200, Appendix VII—States and Local Government and Indian

Tribe Indirect Cost Proposals of this part, and 2 CFR Part 200, Appendix IX—Hospital Cost

Principles. If NIST is identified as the cognizant agency for indirect costs in accordance with

2 CFR § 200.1, within 90 days of the award start date the non-Federal entity must submit

an indirect cost proposal for review. See “Where do I submit my Indirect Cost Rate

Proposal?” for more information. Additionally, NIST will include a Specific Award Condition

with additional information regarding rate negotiation.

RATE AGREEMENT: The document that formalizes the establishment of indirect cost rates

and provides information on the proper application of the rates. Certain award programs at

NIST may have DOC authorized deviations from the Federally negotiated rate agreement.

Refer to DOC FAM 2021-02 for more information.

Types of Indirect Cost

Rates

PROVISIONAL RATE: a temporary

indirect rate applicable to a

specified period used for funding,

interim reimbursement and

reporting indirect costs, pending

the establishment of a final rate.

FINAL RATE: an indirect cost rate

applicable to a specified past

period which is based on the actual

allowable costs of the period. A

final audited rate is not adjustable.

Once determined, the final rate is

used to adjust indirect costs

previously claimed using a

provisional rate.

PREDETERMINED RATE: a

permanent rate established for a

specific current or future time

based on actual costs from a

preceding review period. Typically,

this type of rate is not subject to

adjustment.

FIXED CARRY-FORWARD RATE: a

permanent rate established for a

given period that is subject to later

adjustment. The initial, fixed rate is

based on estimated costs for a

future period; when actual costs

are incurred a carry forward

adjustment is applied. The carry

forward adjustment is the amount

required to reconcile the difference

between the estimated and actual

costs for the agreed upon time

period.

DE MINIMIS RATE: a flat 10%

indirect rate available for nonFederal entities that do not have a 

current negotiated rate with the 

Federal government.

RATE EXTENSION: a non-Federal

entity with a current negotiated rate

may apply, to the cognizant

agency, for a one-time extension of

the existing rate agreement for a

period up to four years. Rate

extension is not available for all

Indirect Cost Rate types.
16

Negotiation of Rates

If NIST is identified as the cognizant agency for indirect costs, in accordance with 2 CFR § 200.1, within 90 days of the award start date

the non-Federal entity must submit an indirect cost proposal for review. Follow the steps outlined in 2 CFR Part 200, Appendices III-VII.

NIST will review the indirect cost proposal(s) submitted by the non-Federal entity and, based on these reviews, must negotiate appropriate

indirect cost rate(s) with the organization. If additional information, or an audit is deemed necessary, NIST or an auditor working for the

Agency will notify the organization of the specific requirements necessary to complete the review of the non-Federal entity’s submission.

The Department of Health and Human Services is the recognized cognizant agency for all institutions of higher education (IHE); NIST

cannot negotiate a rate with an IHE.

The results of each negotiation must be formalized by an indirect cost Rate Agreement signed by the appropriate NIST official and an

Authorized Organizational Representative of the non-Federal entity. Each Rate

Agreement must include the following provisions:

1. The agreed upon rate(s) and information directly related to the use of the

rate(s) (e.g., type of rate, effective period, direct cost base, etc.).

2. The treatment of fringe benefits as either direct or indirect costs.

3. General terms and conditions of the Agreement.

4. Special terms and conditions of the Agreement, if any.

5. Additional information (if necessary) needed by the users of

the Agreement (e.g., the direct charging of a type of cost that is normally

treated as indirect by other non-Federal entities).

Indirect Cost Rate Definitions Continued

COGNIZANT FEDERAL AGENCY: 2 CFR § 200.1“Cognizant agency

for indirect costs means the Federal agency responsible for reviewing,

negotiating, and approving cost allocation plans or indirect cost proposals

developed under this part on behalf of all Federal agencies. The cognizant

agency for indirect cost is not necessarily the same as the cognizant

agency for audit. For assignment of cognizant agencies see Appendix III,

IV, V, and VII to § 200.” NOTE: The Department of Health and Human

Services will be the cognizant Federal agency for all institutions of higher

education for purposes of indirect rate negotiation.

MODIFIED TOTAL DIRECT COST (MTDC): 2 CFR § 200.1: MTDC

means all direct salaries and wages, applicable fringe benefits, materials

and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the sub-awards under

the award). MTDC excludes equipment, capital expenditures, charges for

patient care, rental costs, tuition remission, scholarships and fellowships,

and participant support costs and the portion of each sub-award in excess

of $25,000. Other items may only be excluded when necessary to avoid a

serious inequity in the distribution of indirect costs, and with the approval

of the cognizant agency for indirect costs.

Are we eligible to charge the

de minimis rate of 10%

outlined in 2 CFR § 200.414(f)?

Any non-Federal entity that does not have a 

current negotiated rate, including provisional 

has NEVER had an indirect cost rate 

agreement with the Federal government (with 

a few exceptions described in 2 CFR § 200, 

Appendix VII) may elect to charge a de 

minimis rate of up to 10%of the modified total

direct costs (MTDC). This ratemay be used 

indefinitely. Costs must be consistently

charged as either indirect or direct costs but

may not be double charged or inconsistently 

charged as both. If chosen, this methodology 

must be used consistently for all Federal 

awards until such time as a non-Federal 

entity chooses to negotiate for a rate, which

the non-Federal entity may apply

Where do I submit my Indirect

Cost Proposal?

If NIST is identified as the cognizant agency for

indirect costs in accordance with 2 CFR § 200.1,

within 90 days of the award start date the nonFederal entity must submit an indirect cost

proposal for review to GMDAudit@nist.gov.
17

What happens if there are audit findings?

In the event the audit report includes findings, the non-Federal

entity must prepare a corrective action plan (CAP) to address

the findings as required under the Uniform Guidance, 2 CFR

Part 200. The CAP must include the corrective action intended,

the parties responsible for implementing the corrective action, 

and the anticipated completion date. The non-Federal- entity 

may request clarification from the auditor and must consider 

auditor’s recommendations. Examples of corrective actions 

may include modifying internal controls or procurement

procedures, training, etc. If the non-Federal entity disagrees

with any findings, the CAP must include the response, citing

specific reasons for the disagreement. The CAP must

accompany the audit when sent to the Federal Audit

Clearinghouse.

Audits

Audits shall be performed in accordance with the Single Audit Act Amendments of 1996, as implemented by Subpart F to 2 CFR § 200,

“Audits Requirements.” Non-Federal entities that are subject to the provisions of Subpart F and that expend $750,000 or more in a year in

Federal awards must have an audit conducted for that year in accordance with the provisions of that Subpart. Within the earlier of 30

calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period, a copy of the audit must be submitted

electronically to the Federal Audit Clearinghouse website. The Department of Commerce Financial Assistance Standard Terms &

Conditions, Section D.01.c provides the general audit rules for for-profit entities. It is the recipient’s responsibility to understand and

comply with all audit requirements. Audit costs are an allowable cost as either an indirect or direct charge.

The Need for Audits

The audit provides an independent, cost-effective tool for obtaining information on the non-Federal entity’s financial management practices

and administration of Federal funds. As the recipient of Federal funds, you are responsible to manage the award by establishing and

maintaining internal controls that provide assurances that all requirements can be met; establishing and maintaining an accounting system

that uses generally accepted accounting principles that can

adequately accumulate and segregate costs; and promptly and

accurately prepare financial statements and related documents.

Qualified Auditing Firms

Audits are conducted by a qualified independent auditing firm in

accordance with the Generally Accepted Government Auditing

Standards and guidance provided by Office of Management and

Budget (OMB). Subpart F Audits Requirements of 2 CFR Part 200

outlines the steps and requirements for an auditor. NIST does not

conduct the annual audit, nor can NIST prescribe a specific entity to

perform the annual audit.

Federal Audit Clearinghouse

Annual federal audits and accompanying materials need to be

uploaded into the Federal Audit Clearinghouse website, maintained

by the US Census Bureau on behalf of the Office of Management

and Budget (OMB).

What does audit encompass?

In summary, the audit will be conducted in accordance with the Generally Accepted Government Auditing Standards to ensure:

1) Financial records and statements are presented fairly.

2) Federal award transactions and expenditures are properly identified and tracked.

3) Internal controls and procurement procedures are adequate.

4) Federal laws, regulations, and terms of the federal award(s) are followed.

5) Prior audit findings are corrected.

The auditor must complete and sign the specific sections of the data collection form SF-SAC as required in 2 CFR § 200.512. There

are three reports generated as a result of the single audit: 1) the auditor’s opinion of the non-Federal entities financial statements and

if such statements conform with the U.S. Generally Accepted Accounting Principles, 2) status of internal controls as they relate to the

non-Federal entity’s financial statements and major programs; and 3) opinion regarding the degree to which the non-Federal entity has

complied with laws, regulations and terms and conditions of Federal financial assistance awards. Additionally, the audit will specify

any findings via a Schedule of Findings and Questioned Costs. More information on the scope of the audit can be found in §200.514

Scope of audit.
18

Extension to Closeout

Failure to submit your closeout materials by the end of the

120-day closeout period will put your organization out of

compliance with the terms and conditions of the award and

may result in enforcement actions. Therefore, if you require

additional time to complete any of the closeout

requirements (e.g., pay receivables, complete required

report(s)), you may submit a request for an extension for

closeout. The request must be submitted via

ugam@nist.gov. While the same requirements and

limitations apply to the extension period (e.g., no work or

additional obligations pertaining to the scope of the award),

the extension will provide the necessary time to finish all

administrative related tasks required for award Closeout.

The request must be submitted by the Authorized

Organizational Representative and must include an

explanation for the extension request. The request will be

reviewed by the Federal Program Officer and approved by

the Grants Officer. The extension to the closeout period is

effective upon receipt of a letter amendment from the

Grants Officer.

Award “Closeout”

Closeout is the process by which NIST determines that all applicable administrative actions and all required work under the award have

been completed. The closeout period begins immediately following the period of performance and extends for 120 calendar days. In

accordance with 2 CFR § 200.344 non-Federal entities are to use this 120-day period to finalize administrative tasks related to the award

(e.g. paying invoices, final reporting requirements, financial reconciliation, etc.); non-Federal entities are not allowed to use this time to

finalize work or activities as described in the grant or cooperative agreement statement of work. Refer to the section on No Cost

Extensions if additional time is required to complete the scope of work and obligated funds remain. NIST will issue an official closeout letter

via email approximately 30-days prior to the end date of the award. This letter will include specific instructions and requirements for

closeout of the award. The absence of the closeout letter does not change the non-Federal entity’s responsibilities for closeout activities.

Final Progress Reports

A final progress report is due 120 days after the award period ends. This report must outline the activities and work completed since the last

interim progress report was completed; unless specified in your award this is not a comprehensive (or cumulative) report. It must be 

submitted via email to closeout@nist.gov or as otherwise instructed in the Specific Award Conditions.

Final Financial Reports

A final financial report is due 120 days after the award period ends; the SF-425 is a cumulative report that follows drawdowns and

expenditures throughout the life of the grant. Prior to submitting the Federal Financial Form SF-425, ensure that all funds have been

requested and paid by NIST or drawn down in the ASAP.gov system.

All invoices and bills must also be paid prior to submittal. There must be

zero dollars of cash on hand to closeout an award. The final SF-425

must be submitted via email to closeout@nist.gov.

Other Reports & Requirements

• The Tangible Personal Property report SF-428 is the standard

report used to report all equipment purchased with an

acquisition cost of $5,000 or more.

• The Real Property Report, SF-429, is the standard report for

real property status.

• All non-Federal entities receiving financial assistance from NIST

are required to comply with the standard patent right clause 37

CFR Part 401 and must submit disclosure and elections using

the Interagency Edison Extramural Invention Reporting System

(iEdison).

• The terms and conditions, including Specific Award Conditions,

along with your official closeout letter will provide any award

specific closeout requirements.

• The non-Federal entity must liquidate all obligations incurred

under the award prior to closeout and must refund any

unobligated cash that is not authorized to be retained by the

non-Federal entity.

Post Closeout Responsibilities

There are certain responsibilities that non-Federal entities are required to comply with after the award is closed and all documents

submitted, including without limitation, document retention, audits, and return of funds for subsequently disallowed costs. 2 CFR § 200.344

and the terms and conditions of your award delineate these continued responsibilities. If you are unsure or how to comply with any

requirements, contact your Grants Specialist.
19

Remedies for Non-Compliance

Situations that trigger noncompliance enforcement actions: • Late, incomplete, or inaccurate progress or financial reports.

• Not adhering to federal laws and regulations attached to the grant award,

including the applicable set of terms and conditions and Specific Award

Conditions.

• Certain unauthorized changes to the budget.

• Fraudulent or unlawful activity.

Adhering to rules and regulations outlined in your award and conducting activities as

approved in the project and budget narrative will ensure no enforcement actions will be

taken on the award.

Termination

An award may be terminated by NIST or the non-Federal entity in whole or in part prior to the end of the period of performance.

Terminations by NIST may be for cause or with the consent of the non-Federal entity depending on the circumstance. See

2 CFR § 200.340 for the complete list of paths to award termination, including options for the non-Federal entity to terminate in whole or 

in part. When a Federal award is terminated or partially terminated, both the Federal awarding agency or pass-through entity 

and the non-Federal entity remain responsible for compliance with the requirements in § 200.344 Closeout and § 200.345 Postcloseout adjustments and continuing responsibilities.

If an award is terminated for material failure to comply with the award terms and

conditions, NIST must report the termination in the Federal Awardee Performance and

Integrity and Information System (FAPIIS) for consideration by all Federal awarding

agencies.

It is your responsibility as the

recipient of Federal dollars to be

proactive and engage your Federal

Program Officer and Grants

Specialist when problems arise, or

are anticipated, to avoid or mitigate

the use of enforcement actions.

If a NFE fails to comply with Federal statutes, regulations or the terms and conditions of a Federal award, the Federal 

awarding agency or pass-through entity may impose additional conditions, as described in 2 CFR § 200.332 , Specific 

conditions. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by 

imposing additional conditions, the Federal awarding agency or pass-through entity may take one or more ofthe following

actions, in accordance with 2 CFR § 200.339, as appropriate in the circumstances:

(a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe

enforcement action by the Federal awarding agency or pass-through entity.

(b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or

action not in compliance.

(c) Wholly or partly suspend or terminate the Federal award.

(d) Initiate suspension or debarment proceedings as authorized under 2 CFR § 200.214and Federal awarding 

agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal

awarding agency).

(e) Withhold further Federal awards for the project or program.

(f) Take other remedies that may be legally available.
20

Additional Resources and Links

2 CFR § 200, Uniform Administrative—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for

Federal Awards

Subpart A – Acronyms and Definitions

Subpart B – General Provisions

Subpart C – Pre-Federal Award Requirements and Contents of Federal Award

Subpart D – Post Federal Award Requirements

Subpart E – Cost Principles

Subpart F – Audit Requirements

2 CFR § 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Non-Procurement)

Department of Commerce Financial Assistance Policy, includes links to:

• DOC Financial Assistance Standard Terms and Conditions

• DOC Financial Assistance Memoranda

• DOC Financial Assistance Pre-Award Notice

• DOC Grants and Cooperative Agreement Regulations

Federal-Wide Research Terms and Conditions

Grants Management Forms

Federal Audit Clearinghouse

Online Resources

ASAP.gov

ASAP Customer Service

Bureau of the Fiscal Service

Kansas City Financial Center

Phone: (855) 868-0151

E-mail: asaphelpdesk@fiscal.treasury.gov

Hours of Operation: 6:30 AM - 5:30 PM Central Time (Monday – Friday).

Listen and follow the prompts for ASAP.
21

Glossary

Below is a list of selected terms/phrases and their corresponding definitions for use throughout this Reference Guide. This list is not

intended to be exhaustive; refer to 2 CFR 200, Subpart A for additional definitions.

ADMINISTRATIVE CHANGE LETTER: A letter issued by the Grants Officer notifying the non-Federal entity of changes or modifications

to the award for certain no-cost administrative changes, such as clearance of a Specific Award Condition.

ALLOWABLE COST: An allowable cost is one that meets the criteria for authorized expenditures in the Cost Principles; principally, that it

is necessary and reasonable for the performance of the award and allocable to the award, and not otherwise specifically prohibited.

Allowable cost may also refer to only those categories of costs which have funding included in the approved budget.

AMENDMENT (CD-451): DOC form entitled, “Amendment to Financial Assistance Award.” Any substantive change made to an award is

issued on this form.

AUTOMATED STANDARD APPLICATION FOR AWARD PAYMENT (ASAP): A secure web-based application sponsored by the

Department of Treasury that allows the non-Federal entity to draw funds from accounts pre-authorized by federal agencies.

AWARD AGREEMENT (CD-450): DOC form entitled, “Financial Assistance Award.” Only new awards representing initial funding not

previously funded by NIST are issued on the CD-450.

BUDGET CHANGES: These are deviations from the approved budget that do not involve changes in planned activities or new budget

categories. Changes may need Grants Officer approval, depending on the aggregate amount of change, the total award amount and the

terms and conditions of the award. Refer to Budget Changes and Transfers of Funds Among Categories for more information.

CHANGE IN SCOPE: A change that modifies, adds, or removes key activities, milestones, goals or objectives of the project. Changes in

scope always require Grants Officer and Program Officer approval.

DRAWDOWN FUNDS: For project expenditures, funds drawn down utilizing an automated Government payment system, such as ASAP;

distinct from funds invoiced using the SF-270, Request for Advance or Reimbursement.

FINANCIAL REPORT: Form SF-425, “Federal Financial Report,” submitted by the non-Federal entity summarizing financial performance

during the reporting period specified.

FOREIGN ORGANIZATION: Generally, an entity that is a public or private organization located in a country other than the United States

and its territories that is subject to the laws of the country in which it is located, irrespective of the citizenship of project staff or place of

performance.

PROGRESS REPORT: A report, including the Research Performance Progress Report (RPPR), submitted by the non-Federal entity

summarizing project performance during the reporting period specified. Also known as “Performance” or “Technical” reports to distinguish it

from financial reports.

SPECIFIC AWARD CONDITIONS: These are award-specific conditions imposed when justified by circumstances. These contain relevant 

provisions included in the award agreement, such as publication guidelines, or special restrictions placed on the non-Federal entity

because of Grants Officer’s determinations

SUBSTANTIAL INVOLVEMENT: Collaboration between NIST (the awarding agency) and the non-Federal entity as outlined in the terms 

of a cooperative agreement. The collaboration must be programmatic in nature and provides benefits that would otherwise be unavailable

to the non-Federal entity (e.g., specialized equipment, subject matter expertise).