Compliance
Corner and
Uniform Guidance
Update
MRAM December
2014
Ted Mordhorst
Director for Post Award
Financial Compliance
Research Accounting &
Analysis
Audit News
NSF:
University Audits
Questioned costs:
1. Senior Personnel
salaries exceeding
two months
Ted Mordhorst
Director for Post Award
Financial Compliance
Research Accounting &
Analysis
Audit News
NSF:
University Audits
Questioned costs:
2. Charges near
the end of the
award
Ted Mordhorst
Director for Post Award
Financial Compliance
Research Accounting &
Analysis
Audit News
NSF:
University Audits
Questioned costs:
3. inadequate
documentation
support for other
costs, Travel, Visas
Ted Mordhorst
Director for Post Award
Financial Compliance
Research Accounting &
Analysis
Uniform
Guidance:
Effective
December 26,
2014
MRAM
December 2014
Applicability of the Uniform
Guidance

All new and renewal funding received on or after 12/26/14 is subject to the UG (and
the revised GIMS)

Federal Sponsors may “pull in” existing funding on a project under the UG, when
providing supplemental funding to the project:



Via terms and conditions;
By blanket agency policy.
If Federal Sponsor is “silent” on this issue, UW will treat the entire BN as under the
UG if supplemented with funding received on or after 12/26/14.
Uniform Guidance
Comparing the treatment of certain costs under current
regulation (A-21) vs. the Uniform Guidance (2 CFR
200)(UG)
Items not previously mentioned in A-21
Uniform Guidance
Comparing the treatment of:
Administrative and Clerical Costs
Computing devices
under current regulation (A-21) vs. the Uniform Guidance (2
CFR 200)(UG)
Administrative & Clerical Costs
Now A-21

Criteria for direct charging of Administrative and Clerical
costs under OMB Circular A-21

Funding received prior to 12/26/14

Major project or activity

The project requires an extensive amount of admin or clerical
support.

Significantly greater than the routine level of such services
normally provided by departments.
Administrative Costs Under UG

Criteria for direct charging of Administrative & Clerical
costs under UG effective for new funding received on or
after 12-26-14.

Services are integral to a project or activity;

Individuals specifically identified with the project or activity;

Explicitly included in the budget or have the prior written
approval.

Not included in F&A rate.
A21 & UG
Administrative Costs
Primary difference between A-21 and UG

UG removes the “Major Project or Activity” and extensive
effort criteria

Under UG, If the cost can be justified as “integral” to the
project and the sponsor approves, it is allowable.

Care should be taken to ensure that the actual activity
corresponds to what is justified.
Computing Devices Now
A21
 Computing
devices
 Desktops
and peripherals, Laptops, Tablets, etc.
 Funding received prior to 12/26/14
 Automated
Data Processing (ADP)equipment is
identified as General Purpose Equipment (requires
approval)
 Equipment
= useful life of 1 year + and cost of $2K+
Computing Devices UG
 Computing
 Desktops

devices
and peripherals, Laptops, Tablets, etc.
Cost below $2K treat as a supply item.
 Essential
 Use
and allocable to the award.
is not limited to the award.
($2K & over = General Purpose Equipment)
Computing Devices UG
Definition of equipment remains the same.
 $2K+ and useful life of 1yr+
 Cost
etc.
of the item including shipping, taxes,
Expense under 05-40 or 41
Computing Devices < $2K
Primary difference in treatment (UG).
 UG
 UG
clarifies treatment as supplies.
requires a careful balance between
allocability and use.
Computing Devices < $2K
Primary difference in treatment (A-21).
 A-21
treated as General purpose
Equipment regardless of cost.
 A-21
generally considered use limited to
the award charged or allocate across all
benefiting awards.
 Requires
prior sponsor approval.
Computing Devices UG
Allocable to the award.
 The primary purpose for the purchase is
that the device is necessary to achieve
the objectives.
 Similar
to equipment provisions if excess
capacity exists it may be used for other
activities.

Award activity takes precedence
Computing Devices UG
Computing devices costing $2K and above.
 Classified as General Purpose Equipment.
 Requires
 May
prior sponsor approval.
be used for other activities but
preference MUST be given to other
federal awards.
New Costs in the UG
 Participant
Support Costs

Applicable to awards with training
component or conference

Exempt from F&A
 Sub-budget
used to identify

Requires sponsor approval

May not be rebudgeted without sponsor
approval.
New Costs
 Visa

costs (subset of recruitment costs)
Short Term Visa Costs are allowable
 Critical
and Necessary
 Normally paid regardless of funding source
 Directly allocable to the award

Not long term (immigration) visa costs.
New Costs
 Value
Added Tax (VAT)
 Legally
 Should
required to pay in-country
make every reasonable effort to
obtain exemption if available.
GIM 2: Acceptance of Sponsored Program Awards and
Fiscal Compliance on Sponsored Program Accounts

Reiterates the authority of OSP to accept sponsored
funding.

States the authority of OSP and GCA to oversee central
fiscal processes, systems, and policies related to
sponsored programs.

Emphasizes internal controls by central offices and by PIs
at the project level.*

Pulls in IC/procedural information into the
Procedures/Guidance section from other GIMS and will
allow us to “retire” outdated GIMS (i.e. GIM 6, GIM 14,
GIM 18, GIM 26)
*Guide for PIs/Departments on Internal Control measures in development.
GIM 13: FACILITIES AND ADMINISTRATIVE (F&A)
RATES

GIM 13 policy: Sponsored programs must include full
negotiated rate unless one of the exceptions listed in
GIM 13 applies or a waiver is approved.

UG requires that agencies accept the negotiated rate
of non-federal entities (grantees) unless - 

The agency documents the F&A rate cap in the Funding
Opportunity Announcement (FOA) and agency notified
OMB of the intent to cap the F&A rate.
As a result of UG requirement, OSP does not intend to
approve F&A waiver requests on Federally
funded/Federal flow-through programs. Agency must
comply with UG.
GIM 21: Cost Share on Sponsored Programs
 Cost-share



allowed when:
It is a mandatory requirement of sponsor.
Federally sponsored and included in the FOA is
criteria agency will use during merit review to
consider cost-share commitment.
Non-Federally sponsored, to extent permitted
and necessary due to the competitive nature of
the program.
 Waived
F&A cannot be used as costshare on a sponsored program without
prior sponsor approval.
GIM 23: Sponsored Program Costing policy

All costing principles remain unchanged: Direct
versus indirect; all costs must be necessary,
reasonable, allocable and provided consistent
treatment.

Prior approvals are required for certain costs (see list
in UG, summarized on GCA website), including:



Admin/clerical costs
Participant support costs
GIM now recognizes that costs normally recovered
under F&A may be directly charged to non-Federally
sponsored programs if permitted by the sponsor’s
policies or otherwise approved by the sponsor.
GIM 39: Closeout of Sponsored Programs


Broadened to apply to all sponsored program closeout activity:

OSP will continue to use reports generated from SPAERC to send our
notifications to campus:
 Will continue to be a report of Federally funded programs
 GIM 39 will apply to any severely delinquent sponsored program,
no matter the sponsor, if OSP made aware of the delinquency.

GCA will continue to send Notice of Expiration
All expenditures must be liquidated by 90 days past the end date of
the sponsored program:

This will require heightened vigilance around getting invoices
submitted/received in a timely manner.
New GIM: Subrecipient Monitoring
 UG



requires monitoring of subrecipients:
Risk assessment/evaluation
Decision making on inclusion of specific
terms and conditions in subaward
Monitoring on-going subrecipient activity:



Performance goals achieved
In compliance with subaward terms (e.g.
timeframe, scope of work, budget)
In compliance with regulations (e.g. costing
policy, SFI, animal use, humans subject activity)
Subrecipient Monitoring, continued

GIM includes minimum monitoring steps required at the project level, e.g.:
Receipt of regular progress reports
Approval/rejection of subrecipient’s invoice based on criteria
Tracking of cumulative totals of subaward invoices
Delegation of authority relevant to approval of subrecipient materials is
documented
o
o
o
o

GIM includes central processes implemented to assess and monitor at the
central level (e.g. OSP):
o
o
o
o
o
Use of a risk assessment tool
Issuance of a management decision, when necessary
Initial and annual certifications required of subrecipient
Imposition of conditions in subaward, such as increased frequency of
reporting
Withholding approval of a BPO in the ARIBA system.
Subrecipient Monitoring, continued
 Additional
monitoring steps may be
imposed, depending on risk assessment.
 GIM
gives OSP authority to require a
documented subrecipient monitoring
plan signed by the PI prior to issuance of
the subaward.
Additional tools, resources being developed and a class
on Subrecipient Monitoring is being revised and updated.
QUESTIONS?
THE END