What you will practice
- Separate an error's discovery date from its transaction date when reviewing NIH timing.
- Identify records that connect a proposed charge with the project that benefited.
- Prepare a review packet that names missing evidence and the person responsible for obtaining it.
A practice case for research administrators reviewing corrections to NIH research-grant charges. Uses NIH GPS section 7.5, revised March 2026, and the 2024 Uniform Guidance provisions published by OMB. Check the terms governing the actual award before applying a procedure. All people, awards, transactions and institutional procedures below are fictional. Estimated time is a planning aid; this unit does not award continuing-education credit.
The request on your desk
At fictional Harbor Research Institute, administrator Maya finds invoice CT-184 during reconciliation on September 9, 2026. It posted on May 12 for $4,800 of laboratory reagents, entirely to NIH Award A. An old purchasing template supplied that account code. The purchase request identifies Award B, but the invoice itself contains no project number.
The lab manager supplies a receiving record and a sample log showing that every kit supported Award B's experiment B-14. Both awards were active when the materials were used. Award A is now overspent; Award B has money remaining. Those balances explain why the request attracts scrutiny, but they do not establish which project should bear the cost.
Harbor's fictional procedure requires central-office review when a correction is requested more than 90 days after posting. Maya has the records and emails described here, but no signed certification and no completed review of Award B's restrictions. Your task is to prepare the packet for review, not to approve the journal entry.
Before reading further, write two facts supporting the proposed destination and two unresolved questions. Keep evidence separate from the requester's conclusion.
Keep the two clocks separate
For corrections of clerical or bookkeeping errors transferred to NIH grants, NIH GPS section 7.5 says the correction should be accomplished within 90 days after discovery. It does not set a universal 90-day limit measured from the original transaction. The policy also calls for timely error detection.
In this case, record September 9 as the stated discovery date and May 12 as the posting date. Harbor's additional review requirement still applies. Explain why reconciliation did not identify the template problem earlier; do not change either date to make the packet look timely.
Explain the correction and test the destination
NIH requires an explanation of how the error arose and certification of the new charge's correctness by a responsible organizational official. A generic correction label is inadequate. Meeting the timing expectation does not establish that the new charge is allowable.
Under 2 CFR 200.403, allowability includes necessity, reasonableness, consistent treatment, applicable restrictions and adequate documentation. Section 200.405 ties allocation to benefit; moving a charge simply to absorb a deficit is not justified. Sections 200.302 and 200.303 address supported financial records and documented internal controls.
For this exercise, assemble a readable chain: purchase request, invoice, ledger entry, receiving record and experiment log. Cross-reference their identifiers in the narrative. Ask the reviewer to resolve restrictions or inconsistencies rather than burying them in an attachment. Mark missing material as missing.
Give the correction an owner
Maya proposes replacing the saved purchasing template and asking the purchasing lead to check its next five uses. The central reviewer can request a broader investigation if those checks reveal more errors. This is a suggested response to Harbor's facts, not a federally prescribed sampling rule.
Once the authorized process reaches a decision, link the decision and any resulting journal identifier to the original packet. If the entry is approved and posted, compare both affected ledgers with the requested amounts. A request marked submitted is not evidence that the accounts were corrected.
Build Maya's review packet
Complete the blank response column using only the fictional facts above.
For each gap, identify an owner and the evidence you would request.
Draft a short narrative that explains the original coding and proposed destination without relying on either award's balance.
| Review point | Evidence or response | Suggested owner |
|---|---|---|
| Original entry and proposed $4,800 correction | – | Maya |
| Posting date, discovery date and delayed detection | – | Maya |
| Connection between reagents and experiment B-14 | – | Lab manager |
| Award B restrictions and applicable approvals | – | Central reviewer |
| Certification and decision record | – | Responsible organizational official |
| Template correction and follow-up check | – | Purchasing lead |
Compare your approach with the worked answer
Proposed narrative: Invoice CT-184 posted to Award A on May 12 using an outdated purchasing template. Reconciliation identified the discrepancy on September 9. The purchase request names Award B; the receiving record and sample log connect all kits with experiment B-14. The requested correction removes $4,800 from A and charges B, subject to completed review.
Attach each referenced record and the original ledger detail. Ask Maya to explain the delayed discovery. Route through Harbor's central review because the posting-age condition is met. Do not describe that internal condition as the NIH discovery rule.
The packet is incomplete: the responsible official's certification and review of Award B's restrictions are outstanding. The supplied experiment log supports the proposed allocation, but it does not settle every allowability condition. If the documentation changes, reassess the amount and destination.
Assign the template replacement to the purchasing lead, with a recorded follow-up date. Preserve the review outcome even if the request is rejected. For an approved entry, confirm the $4,800 reduction and addition in the respective ledgers and retain the journal reference.
Check your understanding
Your answers stay in this browser. Create an account to save practice across devices.
Loading your saved practice…
Sources and applicability
Check the terms, policy dates and agreements that apply to your award. These fictional practice cases do not authorize an institutional transaction.
- NIH Grants Policy Statement, March 2026: section 7.5, Cost Transfers, Overruns, and Accelerated and Delayed Expenditures
- OMB, Guidance for Federal Financial Assistance, 89 FR 30046: adopted text of 2 CFR 200.302, 200.303, 200.403 and 200.405