What You Should Know
Effective December 26, 2014, the Office of Management and Budget (OMB) established a new set of regulations for all federal assistance awards (e.g. grants and cooperative agreements) referred to as Uniform Guidance and codified in Chapter 2 of the Code of Federal Regulations, Part 200.
The Uniform Guidance consolidates eight OMB circulars (A-21, A-50, A-87, A-89, A-102, A-110, A-122 and A-133) into a single policy guide and is applicable to Institutions of Higher Education, State and Local Governments, Non-Profit Organizations and Hospitals.
Key Impacted Areas
Administrative & Clerical Salaries
The Uniform Guidance clarifies that salaries of administrative and clerical staff should be treated as indirect (F&A) costs. Direct charging of these costs may be appropriate if all the following conditions are satisfied:
- The services are integral to a project or activity;
- Individuals involved can be specifically identified with the project or activity;
- Such costs are explicitly included in the budget or have prior approval from the federal agency; and
- The costs are not also recovered as indirect (F&A) costs. (UG 200.413)
The Uniform Guidance reminds institutions that financial closeout reports are to be submitted no later than the 90 or 120 calendar days (varies by federal agencies) after the end date of the performance period, and such financial and performance reports, including any due under a subaward, must be received prior to closeout. All final billings must be included in the financial closeout report unless an extension is authorized by the federal sponsor. (UG 200.343)
The Uniform Guidance clarifies that computing devices are generally considered “Supplies” and can therefore be directly charged to federally sponsored projects as long as they are essential and allocable to the performance of a federal award. (UG 200.33) These cost are not required to be solely dedicated to a specific award, and any computing device costing more than $5,000 should be treated as “Equipment.”
Cost sharing is the portion of the total project costs of a sponsored agreement borne by the University or third party, rather than by the sponsor. Two important types of cost sharing are: mandatory cost sharing, which is required by the sponsor as a condition of the award and explicitly enumerated in the proposal; and voluntary committed cost sharing, which is not required by the sponsor, but offered in the proposal by the applicant.
The Uniform Guidance reinforces the fact that voluntary committed cost sharing is neither expected nor considered during merit review of the proposal. Federal agencies must require mandatory cost share or not consider it at all. (UG 200.306)
The Uniform Guidance supports Princeton’s strong discouragement of cost sharing unless mandatory by the sponsor because of its high financial and administrative burden and potential negative effect on the negotiated indirect cost rate.
Strong internal controls provide reasonable assurance that Princeton is managing its award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Uniform Guidance emphasizes the importance of having documented internal controls. (UG 200.303)
Principal Investigator Disengagement
The Uniform Guidance recognizes that PIs can be away from campus and remain engaged in the project. Prior approval from federal awarding agencies must be obtained for the following program or budget related reasons (UG 200.308):
- Change in scope or objective or change in a key person identified in the grant application;
- Disengagement from the project for more than three months or a 25% in committed time.
The Uniform Guidance provides detailed and prescriptive methods by which research institutions should procure goods and services cost more than $10,000 under a federal assistance award. Uniform Guidance emphasizes the documentation requirements and internal written procedures for procurement. (UG 200.317-326)
As of July 1, 2018, Princeton’s procurement procedures comply with the Uniform Guidance requirements.
With prior sponsor approval, fixed price subawards of up to $150,000 are permissible under the Uniform Guidance, provide there is no mandatory cost sharing or matching. (UG 200.332) Additionally, Uniform Guidance clarifies that if a subrecipient does not already possess a negotiated indirect cost (F&A) rate, it may apply a de minimus 10% rate. (UG 200.331)
The Uniform Guidance requires institutions to perform a risk assessment of subrecipients prior to issuing the subaward in order to determine the appropriate level of monitoring. (UG 200.331) Factors to be considered may include:
- Prior experience with same or similar subawards;
- Uniform Guidance Single Audits;
- Personnel or system changes;
- Monitoring by federal agencies.
Recent federal audits and enforcement actions continue to reinforce the need for ongoing monitoring of subrecipients regardless of the risk level assigned at the pre-award stage.
The Uniform Guidance clarifies that costs associated with short-term visas for personnel whose critical skills are required for a specific award may be proposed and charged as a direct cost as long as:
- The skills are critical and necessary for the project;
- The costs are considered direct and allowable under Cost Principles;
- The costs are consistent with University costing accounting policy and procedures.
Expedited processing fees generally remain unallowable under Uniform Guidance.
The Uniform Guidance (2 CFR 200, Full Text)
Preamble - Major Policy Reforms
Subpart A (200.0 - 200.99) – Acronyms and Definitions
Subpart B (200.100 - 200.113) - General Provisions
Subpart C (200.200 - 200.211) - Pre Award Requirements
Subpart D (200.300 - 200.345) - Post Award Requirements
Subpart E (200.400 - 200.475) - Cost Principles
Subpart F (200.500 - 200.521) - Audit Requirements
In addition, the Uniform Guidance Table of Contents is a useful resource.
Compliance & Systems Manager
Sponsored Research Accounting (SRA)