Uniform Guidance Updates: What PI’s and

their staff need to knowApril 2, 2015

Syracuse UniversityOffice of Sponsored Programs

Today’s Agenda

• What is the Uniform Guidance?• High-level goals of the Uniform Guidance• Timeline for changes• Uniform Guidance organization• Key sections of interest for further discussion• Syracuse University’s implementation of the guidance• Questions, concerns, comments?

Reform of Federal Policies related to Grants and Cooperative Agreements• OMB released the ‘final guidance’ on “Uniform

Administrative Requirements, Cost Principals and Audit Requirements for Federal Awards” on December 26, 2013.

• Federal Agencies required to implement their new programs simultaneously, on or soon after December 26, 2014.

Timeline for Rollout • 200.110, Effective Implementation dates

• Federal Agencies must implement effective by 12/26/14

• Admin requirements and cost principles will apply to new awards, and to additional funding increments made on or after 12/26/14.

• Audit section will apply to audits of fiscal years beginning on or after 12/26/14, so this will come into play for fiscal year beginning 7/1/2015 (FY 2016).

• Procurement section, which has significant changes, has been delayed until the fiscal year beginning 7/1/2016 (FY 2017).

What are the high level goals of the Uniform Guidance?• Streamline guidance on federal awards • Strengthen federal oversight of funding, to reduce potential for

waste, fraud and abuse• Set standard requirements for financial award management

uniformly across all federal agencies• Consolidate 8 OMB Circulars into Title 2 of the CFR • Increase efficiencies and effectiveness and reduce administrative

burden of Federal Award making • Expectation is set that grantees have strong internal controls in place

Organization of the Uniform Guidance 2 CFR Part 200

• Subpart A – Acronyms & Definitions• Subpart B – General Provisions (Section 200.1xx)• Subpart C – Pre-Award Requirements (Section 200.2xx)• Subpart D – Post-Award Requirements (Section 200.3xx)• Subpart E – Cost Principles (Section 200.4xx)• Subpart F – Audit Requirements (Section 200.5xx)

Order of Precedence*

1. Award Terms and Conditions2. Program Specific Guidelines3. Agency Specific Guidelines 4. OMB Uniform Guidance

Institutional Policies and Procedures

Public Laws

*This slide is derived from an example presented by NCURA Region II, Uniform Guidance, March 2014

Notice of Funding Opportunities(200.203)• Specifies a set of 6 mandatory data elements (standardization)

• Identifies the full text that must be included in funding opps, (Appendix I of Part 200)

• Establishes minimum timeframe (60 days) that federal agencies must generally make funding opportunities available to applicants

• Note: This is a good move toward standardizing funding opps, and while 60 days lead time is not as good as 90, it is still an improvement

Federal Agency Review of Merit(200.204)• This is new requirement, and helps the small or middle size applicants

understand the ‘playing field’

• Federal agencies must design and execute merit review processes for applications

• The merit review process must be described in the in the funding opp (i.e. - transparency to the applicant)

• Note: This is a good addition that allows applicants to fully understand the merit review criteria, and review process.

Cost Sharing or Matching(200.306)• Clarification is made that voluntary committed cost sharing is not

expected under federal research proposals• Voluntary Committed Cost Share cannot be used as a factor during

the merit review of the proposal• Cost Sharing may only be offered/considered when it’s required by

regulation and transparently displayed in the funding opportunity

Note: This is a great clarification that is similar to NSF’s policy on cost share.

Methods of procurement (delayed until 7/1/16)

(200.318 – 326)• Micro-purchase threshold (<$3,000)

• For such expenditures (in aggregate) cost need only be determined to be reasonable

• Simplified acquisitions ($3,000 - $150,000) • Procurements require documentation of price / cost with at least two quotes,

including review of web / published prices

• Greater than the simplified threshold > $150,000• Procurements use either sealed bid (when price is the sole issue, ordinarily for

construction) or competitive proposals when sealed bid is not appropriate.

• Sole source acquisitions: definition has been updatedNote: Omni-circular Working Group will make recommendations to University leadership for purchasing

policy revisions.

Subaward Management(200.330)

•Must make and document a case-by-case determination as to whether the funding recipient should be a subrecipient, a contractor (formerly known as vendor), or a consultant.

•OSP staff can help with these determinations at proposal stage, and may ask additional questions to clarify the relationships of third party collaborators.

Subrecipient Monitoring(200.331)• F&A guidance is improved; use the subrecipient’s negotiated rates, or

subrecipients without a negotiated rate can get an automatic 10% MTDC rate.

• Agency must grant prior approval for issuing fixed price subawards

• New maximum limit for fixed price subawards $150K

Prior Written Approval(200.407)• New section clarifies that in order to avoid disallowed costs,

recipients can seek prior approval of the agency

• One stop section that provides a comprehensive list of circumstances for which we can seek prior approvals (i.e. – unbudgeted subawards, cost-sharing unrecovered F&A, change in key personnel, etc…)

Note: This section is key for the incurrence of unusual costs or costs that fall in a grey area

Administrative & Clerical Salary as Direct Costs(200.413)• Revised to reflect conditions under which inclusion of admin/clerical staff

salaries may be appropriate, provided that certain criteria are met.FOUR conditions must all be met and described in the budget justification:1.Administrative or clerical salaries are integral to a project or activity;2.Individuals involved can be specifically identified with the project or activity;3.Such costs are explicitly included in the approved budget or have the prior

written approval of the cognizant Agency; and4.The costs are not also recovered as indirect costs.Note: Must be a compelling justification made!

Indirect (F&A) Costs(200.414)• Federal acceptance of approved IDC rates

• Federal awarding agency must accept approved negotiated IDC rates, unless otherwise required by federal statute, regulation, or when approved by agency head or delegate.

• New de minimis rate of 10% for entities that do not have negotiated rates• Any non-federal entity that has a federally negotiated rate may apply for a

one time extension, for a period up to 4 years.Note: These updates are generally helpful to grant recipients, particularly the

de minimis rate when working with Subrecipients that don’t have negotiated rates

Direct Charging Computing Devices(200.453)• The charging of computing devices as a direct cost is allowable for

devices that are essential and allocable, but not solely dedicated, to the performance of an award.

• Computing device must be necessary and reasonable for the performance of the work, but it need no longer be used exclusively for the project.

Direct Charging Computing Devices, cont’d (200.453)Guiding Principles for requesting computing devices•Necessary computing devices may be charged in full to a sponsored project when predominantly used in support of the sponsored project. Indicators of predominant use include:

• Use by faculty: when faculty effort in any amount (including summer) is charged to the grant.

• Use by students or staff: for student / staff positions supported by the project at a minimum full time equivalent of 0.5 each year of the requested project period.

•Computers dedicated to lab or field use for data gathering and analysis or for computation are also allowable.

Participant Support Costs(200.456)• The treatment of participant support costs is now defined uniformly

for all federal agencies and not just NSF• Handled consistently with NSF practice, removed from the MTDC

base and not subject to F&A• Rebudgeting of participant support costs will require prior approval

Publication and Printing Costs(200.461)• Charges that are necessary to publish research results and that occur

after the period has ended are allowable.• ‘The non-federal entity may charge the federal award before closeout for the

costs of publications or sharing of research results if the costs are not incurred during the period of performance of the federal award.’

Note: This enables faculty to publish research results after the award period of performance, but prior to grant closeout.

What’s Next?

• A cross-functional team has been meeting since May 2014 to review the Uniform Guidance and evaluate current and future Syracuse University policies and procedures for proper alignment with these new provisions. This team will make recommendations to University leadership for further analysis and feedback.

• The ‘Omni-circular Working Group’ is comprised of representatives from AMAS, Comptroller’s Office, the faculty, Information Technology and Services, Office of Research, Purchasing & Real Estate, Sponsored Accounting, and Sponsored Programs.

• QUESTIONS??Office of Sponsored Programs, ospoff@syr.edu, x2807

Other Helpful Resources

• COFAR Crosswalks and links to Part 200- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

• http//m.whitehouse.gov/omb/grants_docs

• ‘What faculty need to know (for now) about the Federal Government OmniCircular.

• http://www.osp.syr.edu/forms%20and%20pages/pages/FacultyCommunicationProposalChangesJuly2014.pdf

• Check out some of the webinars available at:• https://cfo.gov/cofar/