Post-Award Compliance: RPPRs, Public Access, and Effort Reporting

Most conversations about NIH grants focus on the front end: how to write a competitive proposal, how to structure your Specific Aims, how to survive study section. But the moment your award lands, the rules change. The focus shifts from persuasion to accountability. And the mechanisms of accountability are not optional — they are the actual cost of the grant.

This post walks through the compliance infrastructure that exists after your award is active: the Research Performance Progress Report (RPPR), the Public Access Policy and what non-compliance actually costs you, effort reporting and why it is audited more aggressively than any other grant area, prior approvals that you probably think are routine but are not, and no-cost extensions (and what happens if you miss the deadline). I finish with a checklist of the things you need to know before your first anniversary report.

The RPPR: what it is and why programme staff read it

The Research Performance Progress Report is an annual (or final) document that summarises what happened on your grant during the reporting period. It is not a contract compliance document — it is a narrative tool, and it is read by multiple audiences with different agendas.

The basic facts: an RPPR is due within 45 days before the anniversary of your budget period start date. If your award began on 1 July 2024, your first RPPR is due by 16 May 2025 (45 days before 1 July 2025). Your grants office will send reminders, but the responsibility is yours. Missing the deadline can delay your no-cost extension approval and trigger compliance holds on future awards.

What goes into an RPPR

An RPPR covers five main sections:

• Research accomplishments. You describe what you have accomplished in relation to your Specific Aims. This is not a free-form narrative — NIH provides structured fields and expects you to tie each accomplishment back to the aims you proposed.
• Key research outputs. You list publications, presentations, datasets, software, and other intellectual outputs. Every peer-reviewed publication from your NIH-funded work must be listed here, with a PubMed Central ID or NIH manuscript ID. This is where non-compliance with the Public Access Policy first surfaces.
• Personnel. You report on the people who worked on the project: their roles, effort levels, and funding source.
• Human subjects and animal care. If your work involves human subjects or animals, you report on IRB and IACUC status, including any new protocols, amendments, or adverse events.
• Inventions and intellectual property. You report on any patentable inventions or technology developed with NIH funding.

The RPPR is not just a bureaucratic exercise. Here is the counterintuitive part: programme officers read the RPPR when your competitive renewal arrives. If your renewal application says "we will generate three peer-reviewed publications in this award period," programme staff will look back at your previous RPPR and see whether you delivered. If you promised an approach in your proposal and the RPPR shows you took a different path, they want to know why. A poorly written or evasive RPPR can undermine a renewal application that is otherwise scientifically sound.

The practical implication: write your RPPR as though a sceptical programme officer is reading it with a highlighter. Be honest about what worked and what did not. If your planned Aim 2 approach failed and you pivoted, say so and explain the results. If you published more than you predicted, that is a story. If you published less, the RPPR is where you get ahead of the question.

RPPR and publication listings

This is where the Public Access Policy becomes consequential. In your RPPR, you list every peer-reviewed publication that resulted from your NIH-funded work. For each, you must provide a PubMed Central ID (PMCID) if the paper is in a journal that participates in PubMed Central, or an NIH Manuscript ID (NIHMS ID) if the paper is under embargo or in an open-access journal.

If a publication is missing from your RPPR, or listed without a PMC/NIHMS ID, that is a compliance flag. Programme staff note non-compliant publications. On your competitive renewal, they will ask: "Why was this paper not in PubMed Central?" You will be expected to deposit it retroactively and explain the gap.

The NIH Public Access Policy: what it actually requires and what non-compliance costs

The NIH Public Access Policy is straightforward: any peer-reviewed article resulting, in whole or in part, from NIH funding must be made freely available in PubMed Central within 12 months of publication.

The mechanisms are two-fold. If your journal does not participate in PMC, the NIH Manuscript Submission system (NIHMS) accepts the author's accepted manuscript and deposits it on your behalf. If your journal is PMC-compliant, the publisher deposits the paper directly. Either way, your responsibility is to know whether the paper is compliant and to track the PMC/NIHMS ID.

What happens if you do not comply

Here is where the stakes become real. Non-compliance with the Public Access Policy is not a warning. It is documented in your grants administration file and specifically flagged in your RPPR. That flag follows your file.

On your competitive renewal, programme officers will see the non-compliant publications. They may request a written explanation. In some cases, they will ask your institution's grants office for a corrective action plan. In rare cases — when non-compliance is systematic and institutional — NIH has recovered grant funds.

But the worst-case scenario is worse than a single grant. If your institution has a pattern of Public Access non-compliance across multiple PIs, it can trigger a compliance review by NIH's Office of Extramural Research. And during that review, all your active awards are at risk, not just the one with the non-compliant paper. The reviewer can place a hold on your ability to receive new competing renewals until the compliance issue is resolved.

The counterintuitive part: many PIs assume they can deposit a paper after the fact if they notice the gap. You can — but the compliance record shows the violation. It is far simpler to deposit the paper within 12 months of publication and never have the issue arise.

How to manage Public Access compliance

The solution is mechanical. Every time you publish a paper based on NIH funding, immediately add it to your My NCBI bookshelf and flag it for PMC deposition if it is not already there. When the PMCID or NIHMS ID is assigned, add it to your records. Before you fill out your RPPR, run a query in PubMed to confirm that all papers are listed and all IDs are current.

Many labs maintain a shared spreadsheet with author, title, journal, publication date, and PMCID. When RPPR season comes, you copy the IDs straight into the form. This takes an hour and prevents a compliance violation that could block future funding.

Effort reporting: the most audited area of federal grants

Effort reporting is the legal certification of how much time you and your team actually spent on NIH-funded work. It is calculated as a percentage of your total professional effort.

Here is the critical point: effort reporting is not an estimate. It is a certification. When you sign a commitment form that says "30 percent effort," you are making a legal statement that you devoted at least 30 percent of your professional time to that project. If you spent 15 percent, you are in compliance violation, period — regardless of how good the science is.

Why effort is audited more than any other area

Federal auditors view effort misstatement as a form of fraud because it directly affects the indirect cost recovery calculation. If you certify 30 percent effort but actually spent 15 percent, your institution has over-recovered indirect costs against that effort. That is money owed back to the government.

Institutional compliance offices audit effort intensively because they face federal penalties if effort misstatements go undetected. NIH Office of Inspector General audits have consistently found that effort reporting is the area most likely to trigger institutional audit findings. Common patterns include:

• Over-commitment. You budget 20 percent effort on an R01 and 15 percent on an R21 and 10 percent on a service grant, totalling 45 percent — but you only have 40 percent available time that is not committed to teaching and other obligations.
• Misalignment between funded effort and actual time. Your budget says you spend 10 percent on the grant, but your lab notes show you spent 5 percent in a given month. Over the course of a year, the discrepancy adds up to under-delivery.
• Cost transfers after the fact. You charge time to a cost pool, then later reallocate it to a grant. Undocumented cost transfers are audit findings.
• Lack of contemporaneous documentation. You certify effort after the fact based on memory rather than timesheets or lab notes. Federal auditors expect contemporaneous (at the time) evidence that matches your certification.

How to stay compliant with effort reporting

The simplest approach is to under-commit and over-deliver. Budget only the effort you are confident you can provide. If you budget 15 percent and actually spend 20 percent, that is compliant. The reverse is not.

Maintain a simple contemporaneous record: a lab notebook entry, a monthly timesheet, or a shared spreadsheet where you note what percentage of your time you spent on the grant in each month. At certification time, you can point to that record and say: "I certify 12 percent effort based on monthly timesheets showing 1.4 calendar months spent on the project across the 12-month period."

If you find that you have over-committed and cannot deliver the budgeted effort, contact your grants office immediately. A cost transfer — formally reallocating the effort to another funding source — is legitimate if documented. An undocumented reallocation is an audit finding.

Prior approvals: what counts as "routine" and what actually requires permission

Many PIs assume they can make certain adjustments to their budget or project scope without asking. They are wrong. NIH requires prior written approval for a surprising number of changes. Missing a prior approval is an audit finding, even if the change was scientifically sound.

Changes that require prior approval

• Change in PI effort of more than 25 percent. If you budgeted 25 percent effort and want to drop to 20 percent, you need approval. If you want to increase from 20 percent to 30 percent, you need approval. The 25 percent threshold is an absolute barrier.
• Change in key personnel. If your grant depends on a specific named researcher and that person leaves, you need prior approval to name a replacement.
• Purchase of equipment not in the original budget. If you want to buy a $50,000 instrument that was not proposed, you need prior approval — even if you have carryover funds.
• Change in project scope or approach. If your Research Strategy proposed one experimental approach and you want to adopt a different one, you need prior approval.
• International travel. Some NIH institutes require prior approval for any foreign travel on the grant. Check your award notice.
• Carryover of unobligated balances. Some award types (fellowships, training grants) have restrictions on carrying money from one year to the next. Check your funding opportunity announcement.
• Subcontract above a certain threshold. If you want to subcontract a portion of the work to another institution and the total subcontract amount exceeds a threshold specified in your award (typically 25 percent of the direct costs), you need prior approval.

The cost of missing a prior approval

Here is the counterintuitive part: missing a prior approval is an audit finding even if the change was good for the science. An auditor will look at your grant file and see that you purchased $50,000 in equipment without documented prior approval. The finding is written up. Your institution must respond with a corrective action plan. On your next federal compliance audit, the auditor will check whether the corrective action was implemented.

Repeated or unresolved prior-approval violations can trigger "questioned costs" — NIH may ask you or your institution to repay the questioned amount. This is rare but not theoretical.

The practical response is to ask your grants office whenever you are unsure. The approval process takes 1–2 weeks. Not asking and hoping to avoid detection is not a strategy.

No-cost extensions: timing, approvals, and what happens if you miss the deadline

A no-cost extension (NCE) is a request to extend your project period by up to 12 months without additional NIH funding. NCEs are useful for completing experiments, finishing manuscripts, or accommodating delays beyond your control.

How NCEs work

You submit an NCE request through eRA Commons at least 30 days (ideally 45 days) before your project period end date. Your grants office submits it on your behalf. You include a brief justification explaining why the extension is needed.

The first no-cost extension is almost always approved if requested in time. Approval is automatic. The second NCE requires scientific justification and is less certain to be approved. The third NCE is rarely approved.

What happens if you miss the deadline

Here is the critical mistake PIs make: they assume they can request an NCE after the project period ends. They cannot. Once your project end date passes, all unobligated balances are lost. They cannot be recovered, even if you request a retroactive NCE.

Example: Your R01 has a project period end date of 30 June 2026. You have $75,000 in unobligated balance and you plan to use it for final experiments in July and August. If you do not submit an NCE request by 16 May 2026 (45 days before), your project period ends on 30 June and the $75,000 reverts to the government. You cannot request a retroactive extension and claim the money.

Your grants office will send reminders, but the responsibility is yours. A single missed deadline can cost your lab real money.

Rebudgeting and transfers: the 25 percent rule

Within a budget year, you are allowed to move money between categories — salary to supplies, for example — as long as the total amount transferred does not exceed 25 percent of your total budget. Any single transfer exceeding 25 percent requires prior written approval.

This is one area where auditors are forgiving if you document the transfer and it is scientifically justified. But the word "approval" is key. An undocumented rebudgeting is an audit finding. A documented request that was approved is not.

Institutional responsibilities vs. PI responsibilities: who owns what

Your grants office handles administration: submitting RPPRs, processing no-cost extensions, maintaining official records. But several compliance responsibilities are on you as PI, and no institutional support absolves you of them:

• Ensuring that every peer-reviewed publication has a PMCID or NIHMS ID in PubMed Central within 12 months of publication.
• Maintaining contemporaneous records of effort and time spent on the grant.
• Certifying effort accurately on your annual commitment form.
• Notifying your grants office of any significant changes to project scope, personnel, or budget allocation.
• Requesting prior approvals at least 30 days before you make a change that requires one.
• Requesting a no-cost extension at least 45 days before the project end date if you need one.

Your grants office is your ally in all of this. They can help you navigate the rules, remind you of deadlines, and draft prior-approval requests. But the ultimate accountability is yours. "My grants office didn't remind me" is not an acceptable explanation to NIH.

Post-award compliance checklist

What happens during a federal audit

Every few years, NIH (or the federal government on NIH's behalf) audits a sample of awarded grants at your institution. An auditor will review your grant file: the budget, the award notice, your RPPR, effort certifications, timesheets, and a sample of charged expenses. They are looking for:

• Effort discrepancies between what was budgeted and what was certified.
• Non-compliance with the Public Access Policy.
• Undocumented cost transfers or unbudgeted purchases.
• Changes that required prior approval but did not receive it.

If an auditor finds a problem, they issue a finding. Your institution is expected to respond with a corrective action plan. If the finding involves questioned costs, NIH may require repayment. Repeated findings or unresolved findings can affect your institution's ability to receive future NIH funding.

The good news: all of this is preventable through simple diligence. Maintain records, ask your grants office when you are unsure, request prior approvals in advance, and deposit your papers in PubMed Central on schedule. No auditor will find what you have documented correctly.