This Quick Guide highlights some of the more significant changes that may impact your new grant applications.The Office of Management and Budget (OMB) has combined many of OMB federal circulars, including A21 and A110, into a single guidance document that can be used by all agencies. This combined document is now known as, "Uniform Guidance." As stated per the OMB webpage, this guidance “will supersede requirements from OMB Circulars A-21, A-87, A-110, and A-122 (which have been placed in 2 C.F.R, parts 220, 225, 215, and 230); Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up.”The new Uniform Guidance rules are effective for new awards made on or after December 26, 2014.
The Uniform Guidance provides detailed and prescriptive methods by which research institutions should procure goods and services costing more than $3,000 under a federal award. The Guidance emphasizes the documentation requirements and internal written procedures for procurement (UG 200.317-326). The OMB is providing a grace period until FY17 to comply with these standards.
The Uniform Guidance reminds institutions that financial close-out reports are to be submitted no later than 90 calendar days 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 close-out. All final billings must be included in the financial close-out report unless an extension is authorized by the federal sponsor (UG 200.343).
With prior sponsor approval, fixed price subawards of up to $150,000 are permissible under the Uniform Guidance, provided there is no mandatory cost sharing or matching (UG 200.332). Additionally, the Guidance clarifies that if a subrecipient does not already possess a negotiated Indirect Cost Rate, it may apply a //de minimis// 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:
The Uniform Guidance clarifies that salaries of administrative and clerical staff should be treated as indirect (F&A) costs. The New Guidance outlines specific conditions under which it may be appropriate charge these as direct costs.
The Uniform Guidance reinforces that voluntary, committed cost sharing cannot be used as a factor during the merit review of proposals unless it is explicitly specified in a notice of funding opportunity.
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).
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:
Fixed amount awards & Subawards (201&332)
Direct Costs (Admin and Clerical - 413)
Materials and Supplies (Computing Devices) (453)
Issued: June 2015