The University of Vermont
To:
Business Unit Administrators
From:
Jennifer Gagnon, Associate Vice President for Research Administration
Subject:
New Federal Regulations for Sponsored Activities: Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards
Date:
January 7, 2015
As promised in my memo dated December 8, 2014, I am writing to highlight a few important
updates on the University’s implementation of the new Federal regulations for sponsored
activities. These changes went into effect on December 26, 2014 and may impact the day to day
financial and administrative management of sponsored projects in your units.
1. Administrative salaries are allowable as a direct charge to federal projects, as long as the
following conditions are met:
a. Administrative or clerical services are integral to a project or activity;
b. Individuals involved can be specifically identified with the project or activity;
c. Such costs are explicitly included in the budget or have the prior written approval
of the Federal awarding agency; and
d. The costs are not also recovered as indirect costs.
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A project no longer needs to be categorized as “major” in order to directly charge
administrative salaries to it.
When administrative salaries are considered integral to a project, investigators must
continue to complete the Direct Cost Justification Form, describing the integral nature of
the administrative or clerical staff member’s effort is to the work of the project.
When integral to the work, administrative or clerical salaries must be included in the
budget and budget justification of the proposal. Please note that the Direct Cost
Justification Form must be submitted and approved by SPA staff prior to proposal
submission.
When administrative or clerical salaries are not included in the proposal but are
determined later to be integral to the work, prior approval from the sponsor is required
before directly charging the effort. Prior approval must be obtained either via annual
progress reports or via separate letter to the sponsor’s administrative office. See below for
additional details.
Associate Vice President for Research Administration
340 Waterman Building
85 South Prospect Street, Burlington, VT 05405-0160
(802) 656-3360 fax: (802) 656-8604
www.uvm.edu/spa/  www.uvm.edu/rpo/
Equal Opportunity/Affirmative Action Employer
The University of Vermont
2. Computing Devices are now classified under materials and supplies and may be directly
charged to a sponsored project if the following conditions are met:
o Devices are essential to the project; and
o Allocable to the project.
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Note that the devices need not be solely dedicated to the performance of the federal
award in order to be directly charged.
Note that the request for computing devices should be included in the proposal budget
and budget justification to the extent possible.
Investigators must continue to complete the Direct Cost Justification Form to describe the
essential nature and allocability of the computing device prior to charging it to the
project.
3. Subrecipient Monitoring
There are two important changes to the issuance and monitoring of subrecipient activity,
resulting from the Uniform Guidance and identified as priorities by the sub and steering
committees:
 UVM must offer its subrecipients of Federal funds a deminimis F&A rate of 10% if the
recipient does not already have a Federally-negotiated rate. UVM will alert subrecipients
of this option via the Subrecipient Commitment and Audit Certification Form completed
by all proposed subrecipients during proposal development.
 UVM must now document the review of subrecipient performance reports. Working with
investigators, SPA will include in subaward agreements the explicit requirements for
subrecipient completion of final performance reports. When reviewing the final invoice
from the subrecipient, UVM PIs will confirm their receipt of the subrecipient
performance report and approve the final subaward invoice for payment at the same time.
4. Requests for Prior Approval & Associated Requirements
The Uniform Guidance outlines many new circumstances under which sponsor prior
approval is required, including the following:
 Pre-award spending;
 No-cost extensions (even first time occurrences); and
 Direct charging of administrative or clerical salaries.
Sponsor prior approval remains required for a number of other additional circumstances,
including:
 Change in scope of work;
 Disengagement of the PI or key personnel for more than three months; and
 Reduction in effort of the PI or key personnel by more than 25% of the commitment.
Associate Vice President for Research Administration
340 Waterman Building
85 South Prospect Street, Burlington, VT 05405-0160
(802) 656-3360 fax: (802) 656-8604
www.uvm.edu/spa/  www.uvm.edu/rpo/
Equal Opportunity/Affirmative Action Employer
The University of Vermont
Sponsor prior approval may be sought via a formal request to a sponsor’s administrative
contact and sometimes via a regular performance report to the sponsor. As a reminder, all
requests for prior approval must conform to the sponsor’s specific requirements and follow
the same procedure:
 Requests must be reviewed by SPA and endorsed by an Authorized Institutional Official
(typically the Director of SPA or Associate Vice President for Research Administration)
prior to submission to the sponsor;
 Requests must be submitted to the sponsor’s administrative contact;
 Sponsor approval must be received prior to the requested action taking place.
We will continue to provide updates to you and the principal investigators in your units as and
when issues and solutions are crystallized. Please refer to the SPA Uniform Guidance site and
the Cost Policy site for additional helpful information.
Associate Vice President for Research Administration
340 Waterman Building
85 South Prospect Street, Burlington, VT 05405-0160
(802) 656-3360 fax: (802) 656-8604
www.uvm.edu/spa/  www.uvm.edu/rpo/
Equal Opportunity/Affirmative Action Employer