Upload
others
View
0
Download
0
Embed Size (px)
Citation preview
at 2 CFR 200
Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards
February 13, 2015
AGENDA
• What is Uniform Requirements?
• What projects are affected and when?
• What changes are most important to faculty and research performers?
• What is NOT changing?• What’s next??
With apologies to Bob Dylan…
Come gather you people wherever you roam…..
For the times they are a changin’
02/13/2015 2 CFR 200 Overview of Changes 2
Grants Reform
• Office of Management and Budget Circulars combined into Uniform Requirements
• A‐21, A‐110, A‐133 replaced
• Effective for awardsand new funds awarded December 26, 2014 & after
ORDER OF PRECEDENCE: CONTROL OF A SPONSORED PROJECT
Award
Special Conditions
Program Rules(found in the solicitation)
Agency Rules (found in agency general terms and conditions)
Uniform Requirements(2 CFR 200)
State Laws & Regulations
Institute Policies
02/13/2015 2 CFR 200 Overview of Changes 3
4
Uniform Requirements – What’s Covered
• Administrative Requirements– Finances– Purchasing– Property
• Solicitations, Proposals, and Awards• Allowable Costs
– Direct and Indirect– Personal Services (Effort Reporting)– Space and Utilities
• Facilities and Administrative Cost Calculations
402/13/2015 2 CFR 200 Overview of Changes
MAJOR CHANGES
02/13/2015 2 CFR 200 Overview of Changes 5
Program performance must reflect financial
performance• Similar to ARRA
reporting
Emphasis is on internal controls and
documentation• Timely appointments
and cost transfers• PI Certification• More requirements
that are “must” rather than “should”
Subawards• Pre‐award documentation
required
• Limits on fixed price
• Payment requirements
• Greater financial and programmatic performance monitoring
Planning is Important!• Proposing fixed price • Subawards• Purchasing will require
more quotes and bids• Close‐out timeline will
be compressed
WHAT CHANGES ARE MOST IMPORTANT TO FACULTY AND RESEARCH PERFORMERS?
02/13/2015 2 CFR 200 Overview of Changes 6
Proposals Purchasing Materials & Supplies Equipment
• Solicitation• Cost-sharing cannot
be considered in review and requires agency head approval
• Agencies are expected to pay the full negotiated F&A
• Documentation standards have changed
• Micro-purchasing threshold reduced from $10,000 to $3,000
• DELAYED UNTIL 7/1/2016
• Accounting for residual supplies and documentation for late-term charges
• New cost-transfer limitations
• Equipment purchased with federal funds must be made available to other federally-funded projects
• Additional closeout / disposition requirements
6
WHAT’S NOT CHANGING?
702/13/20152 CFR 200 Overview of Changes
COST ACCOUNTING STANDARDS
• Must be consistent in how you estimate costs for proposals and how you charge costs for projects
• Like costs in like circumstances must be treated in the same manner
• Unallowable costs cannot be billed to the sponsor
• Institutional fiscal year = cost accounting period
02/13/2015 2 CFR 200 Overview of Changes 8
9
NEXT STEPS
• Agency Specific Requirements– NSF published new PAPPG
• OMB Published Technical Corrections and Agency Specific Exceptions on December 19, 2014
• Procurement Requirements delayed until July 1, 2016 for GT
• F&A changes effective July 1, 2015– GT preparing its proposal NOW
• GT Team will be issuing policy revisions at appropriate times
9
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards at 2 CFR 200 became effective December 26, 2014 for new awards.
02/13/2015 2 CFR 200 Overview of Changes
02/13/2015 2 CFR 200 Overview of Changes 10
WATCH FOR
Department of Defense• Implemented on Interim Basis • Revising grant guidelines• Mulling greater use of
Other Transaction Authorities
Statutory Requirements on F&A Recovery or Cost Sharing
• Department of Agriculture• Department of Education• Department of Energy
Cost‐transfers and Close‐out Procedures
• Timing of invoice review, payment and close‐out for subcontracts In!AND Out!
• Time allowed for cost transfers to be shortened
Internal Control Tools• Enhanced project
management tools with drill‐down capability
• PI/PD Certifications for costs
Changes in Procurement and Asset Management
• Bid & Quote Procedures• End‐of‐project Inventory• Equipment Sharing
AGENCY SPECIFICS: https://cfo.gov/wp‐content/uploads/2014/12/Agency‐Exceptions.pdf
MORE INFORMATION
http://www.osp.gatech.edu/uniform‐administrative‐requirements
02/13/2015 2 CFR 200 Overview of Changes 11