Overview of the Uniform Guidance, 9/30/2014

Uniform administrative requirements, cost principles, and Audit Requirements for federal awards (2 CFR 200)

On December 26, 2013, the Council on Financial Assistance Reform (COFAR) released new guidance which we will refer to here as Uniform Guidance.  As an overview, the new guidance:

  • Consolidates 8 federal circulars (A-102, A-110, A-89, A-21, A-87, A-122, A-133, A-50) into a single comprehensive grants management policy guide
     
  • Is effective for all new awards and incremental funding awarded on or after December 26, 2014
     
  • Includes audit requirements (Subpart F) which will apply to audits of fiscal years beginning on or after December 26, 2014 --- for us, this will be fiscal year 2016 (July 1, 2015-June 30, 2016)

The overall objectives of the guidance are to reduce administrative burden while improving oversight and accountability.

Based on our initial assessment, while the new guidance is broad and provides additional clarifications, it is generally consistent with the current guidance.  FAQs recently released by COFAR encourage us to start submitting proposal budgets that are consistent with the new guidance.  The Division of Sponsored Programs has developed Developing Proposal Budget Under the New Uniform Guidance to assist you with this. 

As an overview, the following are some important points regarding the new guidance:

  • Administrative and Clerical Salaries are still normally considered indirect (F&A) costs, but the major project exceptions were removed.  They can be direct charged under the following circumstances: 1) the services provided are integral to the award; 2) the individual can be specifically identified with the activity; 3) the costs are explicitly included in the budget or have prior written approval of the Federal agency; and 4) the costs are not also recovered as F&A.
     
  • Computing Devices (under $5000) are now specifically identified within the guidance.  When the cost is less than $5000, they are categorized as supplies and are allowable as direct costs when the device is essential and can be charged (allocated) to the project based on a measurable direct benefit to the project.  Computing devices that are general purpose in nature continue to be unallowable as direct costs. 
     
  • Participant Support Costs are defined as costs for stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (not employees) in connection with conferences or training projects.  Participant support costs are allowable as direct costs only with prior approval from the sponsor.  Additionally, prior approval is also required to move any approved participant support costs to another budget category.
     
  • Costs for conferences (which are defined as a meeting, retreat, seminar, symposium, workshop or event) are only allowed when the purpose is the dissemination of technical information beyond the university.  Previously the guidance did not include this distinction.
  • Entertainment costs are now specifically identified in the guidance.  These costs continue to be unallowable as a direct cost unless there is a specific programmatic purpose and the sponsor has approved the costs.  
     
  • There are new obligations to document risk assessment and monitoring activities of sub-recipients.  We are continuing to review these requirements and will be modifying our current policies and procedures to reflect the new requirements. 
     
  • Sponsors are required to use federally negotiated F&A Rates unless specifically prohibited by Federal statute.  If one of our subrecipients does not have a negotiated rate, we are allowed to use a 10% de minimus rate. 
     
  • Five allowable types of procurement methods are identified and include additional documentation requirements.  In the most recently released FAQs, COFAR is allowing a grace period of one full fiscal year after the effective date of the guidance to implement the new standards.  For us this will be June 30, 2016.  We are continuing to review the requirements to determine how this will impact us. 
     
  • The use of fixed price agreements with our subrecipients now requires prior agency approval and is capped at $150,000. 
     
  • Agencies should not expect us to include voluntary cost sharing in a research proposal and it cannot be used as a factor during the merit review of applications unless explicitly described in the notice of funding opportunity.

Keep in mind that the Uniform Guidance will be implemented by the Federal agencies through their own policies.  With the exception of NSF (see draft Proposal and Award Policies and Procedures Guide), we may not see agency implementation plans until December. 

Grant Accounting has established a new website to provide updates and we will distribute additional communications as we get closer to the implementation date.