The Consolidation of the
OMB Circulars:
Exploring the
“New” Administrative Rules
OMB Uniform Guidance
2 CFR 200
Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for
Federal Awards
http://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/201330465.pdf
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OMB Uniform Guidance
• Issued as final December 26, 2013 and as
guidance to federal agencies
• Effective December 26, 2014
• Audits only—effective with first fiscal year after
December 26, 2014
• Agencies required to implement; must have
submitted their implementation plans to OMB
by June 26, 2014
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A-21
A110
A-87
2 CFR
200
A122
A-50
A133
A-89
A102
The OMB Guidance is a
combined, “simplified”
version of 8 previous
circulars
2 CFR 200
Subpart A – Acronyms and Definitions
Subpart B – General Provisions
Subpart C - Pre-award Requirements &
Contents of Federal Awards
Subpart D – Post Federal Award
Requirements
Subpart E – Cost Principles
Subpart F – Audit Requirements
Appendix
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OMB GuidanceCirculars
Subpart A, Acronyms and DefinitionsA-110, -21, -133
Subpart B, General Provisions A-110, -21, -133
Subpart C, Pre-award Requirements and Contents of Federal
AwardsA-110
Subpart D, Post Federal Award Requirements A-110, -133
Subpart E, Cost Principles A-21
Subpart F, Audit Requirements A-133
Appendices  A-110, -21, -133
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Remember….
As with the old Circulars, the Guidance provides:
•
MAXIMUM REQUIREMENTS THAT THE FEDERAL
AGENCIES CAN IMPOSE
•
MINIMUM STANDARDS FOR AWARDEES
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Effective Date of the UG:
• AS OF THE FEDERAL AWARD DATE TO NEW AWARDS AND, FOR
AGENCIES THAT CONSIDER INCREMENTAL FUNDING ACTIONS ON
PREVIOUSLY MADE AWARDS TO BE OPPORTUNITIES TO CHANGE
AWARD TERMS AND CONDITIONS, THE FIRST FUNDING
INCREMENT ISSUED ON OR AFTER 12/26/14.
• [REGARDING THE LATER,] FEDERAL AWARDING AGENCIES MAY
APPLY THE UG TO THE ENTIRE FEDERAL AWARD THAT IS
UNCOMMITTED OR UNOBLIGATED AS OF THE FEDERAL AWARD
DATE OF THE FIRST INCREMENT RECEIVED ON OR AFTER
12/26/14.
• ONE YEAR GRACE PERIOD FOR PROCUREMENT REQUIREMENTS7
Subpart A – Definitions of Note
• 200.12 Capital assets – includes
software
• 200.20 Computing devices
• 200.48 General purpose equipment –
includes information technology
equipment and systems
• 200.58 Information technology systems
– includes computing devices and
software
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Subpart A – Definitions of Note
• 200.75 Participant Support Costs – stipends or
subsistence allowances, travel, and registration
fees paid to or on behalf of participants or
trainees (but not employees) in connection with
conferences or training projects
• 200.80 Program Income – includes license fees
and royalties on patents and copyrights.
• 200.89 Special purpose equipment
• 200.94 Supplies – clarifies when a computing
device is a supply
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Subpart E – Cost Principles
PREDICATED ON FACT THAT THE GOVERNMENT PAYS
ONLY ITS FAIR SHARE (NO CHANGE)
200.400 Policy Guide
• Continues the acknowledgement of dual
role of students
200.401 Application
• Incorporates CAS provisions
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Subpart E – Cost Principles
200.403 Factors affecting the allowability
of costs
200.404 Reasonable costs
200.405 Allocable costs
Still in play; for a cost to be allowable it must
be necessary, reasonable, and allocable;
conform to award limitations; be uniformly
consistent with policies and procedures; and
be accorded consistent treatment
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Allowability of Costs: Allocation Methods
• Distribution methods must be
reasonable and must be documented.
• The basis for the allocation should
relate to the work being performed.
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Subpart E – Cost Principles
200.413 Direct Costs, (c) relating to administrative
and clerical salaries
“The salaries of administrative and clerical staff
should normally be treated as indirect (F&A) costs.
Direct charging of these costs may be appropriate
only if all of the following conditions are met:
1.
2.
3.
4.
Administrative or clerical 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 the
prior written approval of the Federal awarding agency; and
The costs are not also recovered as indirect costs.”
• Removal of “major project” requirement
• Recognition of administrative workload
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Immediate Impact
• Effective immediately, if there is a potential to directly
allocate administrative and clerical effort to a project, a
justification must be included in the proposal.
• The justification must address the four items on the prior
slide.
• For existing awards that qualified as “major” under A-21,
prior approval to continue directly charging such costs
during the next incremental award period might be
needed. Refer to the terms and conditions of the award or
specifically ask the federal awarding agency.
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Case Study – Administrative and
Clerical Salaries
• Dr. Yunau’s research study involves interviews with study
participants. The interviews need to be transcribed for
purposes of data analysis. The transcription will be done by one
of the department administrative staff person. Each of the 100
participants will have three 60-minute interviews over a sixmonth period. The administrative staff person will spend
approximately one-third of her time performing the
transcriptions during the six-month period.
• Are the UG criteria met, thus supporting direct charging onethird of the staff person’s compensation to Dr. Yunau’s study?
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Case Study – Administrative and
Clerical Salaries
• Dr. Evergreen’s research study involves questionnaire
completion by study participants. The questionnaires need to
be printed and mailed. Once returned, the responses need to
be entered into a special database that will be used for data
analysis. The tasks will be done by one of the department
administrative staff person. The administrative staff person will
spend approximately ten percent of his time performing the
transcriptions during the next year.
• Are the UG criteria met, thus supporting direct charging ten
percent of the staff person’s compensation to Dr. Evergreens
study?
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Subpart E – Cost Principles
Selected Items of Cost
200.453 Materials and supplies costs, including
costs of computing devices
• acknowledgement of computing devices as a
supply cost
• Note wording “In the specific case of computing
devices, charging as direct costs is allowable for
devices that are essential and allocable, but not
solely dedicated, to the performance of a Federal
award.”
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Case Study – Computing Devices
• Dr. Sturtevant has a sponsored project whose study participants
are nursing home residents. The project involves assessing
participant cognitive skills using special gaming software. A
laptop will have the special gaming software. Dr. Sturtevant’s
research assistants will take the laptop to nursing homes.
During the next two years, approximately 70% of the time the
laptop will be used for the project. The rest of the time the
laptop will be used for general research purposes.
• Does the laptop qualify as a direct cost for Dr. Sturtevant’s
project?
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IS THIS ALLOWABLE?
While I’m traveling to collect data. I need to
keep in touch with my office so I need an
I-Phone.
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IS THIS ALLOWABLE?
I need a new laptop. I want to buy it on
my grant which runs for another year.
What if the grant terminates in 2 months?
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IS THIS ALLOWABLE?
I have just purchased a laptop for use on
my grant and other administrative work for
the University. I will charge 50% of the
laptop to my grant.
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Subpart E – Cost Principles
Selected Items of Cost
200.463 Recruiting Costs
• Requirement to repay if employee resigns within
twelve months after hire remains
• Short-term visa costs (as opposed to longer-term,
immigration visas) are generally allowable.
• Short-term visas are issued for a specific period
and purpose and should be clearly identified as
directly connected to work performed on the
award.
• Must be critical and necessary for the conduct of
the project
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IS THIS ALLOWABLE?
My foreign graduate student will be
conducting research on one of my grants.
I want to charge the costs of her J-1 visa
to the grant.
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Immediate Impact
• For federal grants with effective dates of 12/26/14 or later,
the Uniform Guidance provisions are applicable to the preaward spending (i.e. spending 90 days prior to award
effective date).
• Pre-award spending is at the entity’s own risk, since the
terms and conditions of the award are not yet known.
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One Last Thing….
Order of Precedence
Statute
Administrative
Regulations
OMB Circulars/
Guidance
FAR
Program Regulations
Special Terms and Conditions
of Award
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