uniform guidance overview - Research

Report
UNIFORM GUIDANCE
OVERVIEW
OMB Circulars Before and After
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A-21 Cost principles for Educational
Institutions
A-110 Uniform Administrative Requirements
for Grants and Other Agreements with
Institutions of Higher Education, Hospitals
and Other Non-Profit Organizations
A-133 Audits of States, Local Gov’ts and
non-profit Organizations
A-87 Cost Principles for State, Local and
Indian Trial Governments
A-122 Cost Principles for Non-Profit
Organizations
A-89 Catalog of Federal Domestic
Assistance
A-102 Grants and Cooperative Agreements
with State and Local Governments
A-50 Audit Followup
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Uniform Administrative
Requirements, Cost
Principles, and Audit
Requirements for Federal
Awards
Important Dates
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Applicable to new awards and new funding increments issued on
and after December 26, 2014
UG is actually guidance to agencies and each agency must
submit a draft implementation by June 26, 2014
We expect to see Final Agency implementations some time
before or on December 26
Project will not be “done” by December 26, agency
implementations and further OMB clarifications will necessitate
further review and changes
Issues of Interest
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200.112 Conflict of Interest. This is new section and it is
not clear if this means investigator COI or Purchasing COI
200.307 Program Income. Not clear how this relates to
royalty income
200.317 – 326 Procurement Standards. It is unclear what
type of documentation will be necessary for purchases
between $3,001 and $150,000
200.303 Internal Controls. Many references to internal
controls
Issues of Interest
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200.313 Equipment. New terminology and requirement for
additional information in property records
200.330 Subrecipient and contractor determinations. May
require documentation of decision to use one or the other
200.331 Requirements for pass-through entities.
Requirements for subrecipient monitoring may require
additional documentation of risk assessment of each entity,
review of financial and programmatic reports, audit follow up
Issues of Interest
200.343 Closeouts. Concern that there will be less
flexibility in meeting the 90 day closeout requirement
 200.419 Cost accounting standards and disclosure
statement. CAS still applies.
 Prior approval. Many references to written prior agency
approval
 Note: Some active awards will be under old guidance,
some under new during a transition period
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Positive Changes
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200.203 Notice of funding opportunities. Announcements must
include certain minimum information and should be available for at
least 30 days
200.301 Performance measurement. Clarification received that
standard progress reports, such as the RPPR, are acceptable
methods to document performance on research awards
200.306 Cost sharing or matching. Voluntary cost sharing
committed in the proposal is not expected and cannot be used
during merit review
Positive Changes
200.335 Electronic records are acceptable
 200.414 Negotiated F&A rate must be used by federal
agencies unless required to do otherwise by statute or
regulation or approval of agency head; if the subrecipient
has a federally negotiated rate, the sub must include that
rate [200.331(a)(4)], if it does not, we may use 10%
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Potential Opportunities
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200.413 Direct costs. Although salaries of administrative and
clerical staff are still normally to be treated as indirect, there is new
language that may offer flexibility regarding when it may be
appropriate to charge as direct
200.430 Compensation – personal services. New language allows
some flexibility in documenting personnel expenses (including
faculty)
200.453 Materials and supplies costs, including costs of computing
devices. May allow some flexibility to charge computing devices to
grants.
University of Kentucky Plan
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Steering Committee
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Eric Monday, Executive VP for Finance for Finance and Administration
Lisa Cassis, Interim Vice President for Research
Provost Office Representative
Working Group
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Co-Chaired by Jennifer Miles, Director Sponsored Projects Accounting and Deborah
Davis, Associate VP for Research, Director Office of Sponsored Projects Administration
Includes faculty, associate deans for research, center director, college level business
officer, directors of administrative units affected by UG (HR, Purchasing, Risk
Management, General Accounting, Legal Counsel, Graduate School, Accounts
Payable…..)
And co-chairs are consulting with Subject Matter Experts not on the Working Group
Working Group Responsibilities/Timeline
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Compare new and old guidance
Identify UK policies and procedures
that comply with old and identify
necessary changes
Look for opportunities to be less
restrictive
Draft changes to policies and
procedures
Prepare education and communication
plan to disseminate to campus
Provide education
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May 2014
June 2014
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June 2014
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July – September 2014
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September - October 2014
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October – December 2014
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Communication/Feedback
Town Hall general campus briefings
 Faculty meetings
 Webinars sponsored by professional groups
 Provost Budget Officers
 Existing Listservs
 Website
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Resources/Information
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Uniform Guidance Federal Register Announcement
http://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/2013-30465.pdf
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Chief Financial Officers Council (COFAR) Includes FAQs
https://cfo.gov/cofar/
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UK Uniform Guidance webpage

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