Uniform Guidance:
9 Ways Revised Regulations
May Affect Your Federal Grants
Presented by
Stephanie Lezotte
Office of Sponsored Programs
lezotte@rowan.edu
x4124
UG = 2 CFR 200 = Revised Guidelines for Federal GRANTS
Start Budgeting!
Why: Eliminate Duplication and Conflict
Why: Eliminate Duplication and Conflict
Now:
UG Challenges and Impacts
How UG affects your existing federal
grants
Issued prior to 12/26/14 Issued on/after 12/26/14
• Follows existing Terms and • Automatically follows UG
Conditions UNLESS a
• Fed agencies are revising
modification is issued that
their policies based on
changes the Terms
their interpretation of UG
• Yearly increments MAY
follow UG
• OSP will notify PI of any
unanticipated Term
changes
9 things you should know about UG
#9: Subawards
– More prescriptive requirements
• OSP must perform a risk assessment of the subrecipient – Audit
findings, F&A rate, debarment/suspension, previous experience
• Add subaward flow-down terms and conditions
• Establish a monitoring plan for the subrecipient - review financial
and progress reports (PI/OSP)
– Must use subrecipient’s negotiated F&A rate or provide a
10% MTDC “de minimis” rate
– Fixed fee subawards under cost-reimburseable grants are
allowed up to $150k
BL: Possibility of delays in issuing subawards or reimbursing sub recipients
#8: Clerical/admin 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.”
BL: PIs may include these costs in proposal budgets now with a
strong justification. Approval is NOT automatic.
#7: Procurement
• Significant changes to procurement and
property
• Requires use of specific procurement methods
– Highly prescriptive
• Micro-purchase – exempt from competitive bid
if purchase is $3,000 or less
• Sole Source - Covers unique purchases (subs)
• One year grace period before implementation
• BL: Possible future procurement delays
#7 Procurement “Bearclaw”
#6: Computing Devices
Computing devices means machines used to acquire, store, analyze,
process, and publish data and other information electronically, including
accessories (or “peripherals”) for printing, transmitting and receiving, or
storing electronic information. (200.20)
• 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. (200.453)
BL: PIs can include these costs in proposal budgets as supplies with a
justification
• -A supply is an item with an acquisition cost less than $5,000.
Subject to F&A.
#5: Prior Approvals
Examples where prior approval is required:
– Unrecovered F&A as cost sharing
– Fixed price subawards
– Charging administrative salaries
– Participant support costs changes
– Unusual cost items
BL: New emphasis on agency prior approvals may slow down
research activities
– Not clear that Federal agencies have adequate staffing to
respond quickly
#4 Financial Reporting
Clear directive/more pressure for funding agencies to relate
financial data to performance requirements of the federal award
– Look out! DATA Act coming
BL: Start thinking in terms of project milestones and costs.
Touch base with OSP when necessary so there are no delays in
final financial reports
#3 Cost Share
Restrictions on voluntary committed cost share:
• No more statements of cost sharing being “encouraged”
• If required, CS must be explicitly described in merit criteria
BL: If cost share is not part of the merit review, don’t volunteer it.
#2 F&A Rates
• Agencies must accept approved negotiated rates with a few
exceptions, including where prohibited by law
• Exceptions must be posted to OMB site
– How does this get applied in practice?
– How does this affect federal flow-thru funding?
– Will the 8% training rate be abolished?
• Participant support costs are now exempt from F&A
-Formerly only NSF
#1 Effort Reporting
• Flexibility in how this is done
• Requires adherence with internal controls
– But no specific guidance on acceptable standards
for "internal controls"
• Any significant changes will require auditor
input over time
BL: Rowan will be evaluating its Effort Certification process and keeping a
close eye on what other schools do
Open Issues: Stay Tuned
•
•
•
•
•
Agency deviations – how will these be policed?
Conflict of Interest–agency plans
Procurement – could be most significant new burden
Subrecipient Monitoring–could be second most significant
Effort Reporting - where do we go from here and when?
How OSP Prepared for 12/24/14
• Streamlined compliance reviews for proposals and grants
• Created subaward recipient monitoring checklist and risk
assessment
• Worked with Accounting Services to add additional account
codes in Banner to accurately track expenditures
• Attended online and in-person trainings delivered by White
House officials and professional groups
• Revising existing policies to reflect UG
Questions? Answers are in the Crystal Ball….