OMB Uniform Guidance 2014
Implementation at the University
of Washington
Northwest Chapter of Internal Auditors
August 5th , 2014
Ted Mordhorst
Asst. Dir. For Post Award Financial Compliance
Research Accounting and Analysis
University of Washington
OMB Uniform Guidance 2014
 Final Guidance document published in the Federal Register Dec
26, 2013.
 Codified in 2 CFR 200
 Replaces 8 previous OMB Circulars:
 Circular A-110 Circular A-21
 Circular A-102 Circular A-87
 Circular A-89
Circular A-102
 Circular A-133 Circular A-50
OMB Uniform Guidance 2014
 Applicable to Direct Federal Grants, Cooperative Agreements
and Cost-reimbursable contracts.
 Each federal awarding agency must implement
 Effective for new $ received on or after Dec. 26, 2014
 Audit effective for the entities first full fiscal year after
12/26/14.
 Example: Entities fiscal year ends June 30th
 New audit requirements apply to fiscal year that ends June 30, 2016
University of Washington Approach
A Core Team has been assembled
• Sponsored by Mary Lidstrom, Vice Provost for Research
and Susan Camber, Associate Vice President, Financial
Management
The team has representatives from:
OR, OSP, GCA, MAA, School of Medicine, College of Arts and
Sciences, Procurement Services, and Internal Audit, The AG
office
Additional sub-teams have been formed to review some of
the more complex areas.
University of Washington
Presenter’s Office
Uniform Guidance Working Group
The working groups compared the new regulation to
the existing regulations in A-110, A-21 and A-133
Identify changes
Map changes to university policy and procedures
Identifying possible changes to IT systems both
central and in units
Propose changes to policy, procedures necessary to
maintain compliance
University of Washington
Presenter’s Office
Uniform Guidance Working Group
Develop internal Communication plan.
Develop protocol for making changes to policies and
procedures.
Develop training for campus personnel.
Modify existing training material for faculty and
staff.
University of Washington
Presenter’s Office
Uniform Guidance Working Group
 Timeline
 APRIL 15 DISCOVERY (initial discovery of what changed complete)
 MAY 15 DISCOVERY (impact to UW systems complete)
 JUNE 01 DISCOVERY (map to UW policy & procedure complete)
 JUNE 26 FEDERAL PLANS RELEASED (Federal agencies release their
respective implementation plans)(Has not happened.)
 SEPT 30 DRAFT OF CHANGES TO UW POLICY (comprehensively
address & publish all changes to UW policy)
 DEC 01 UW READY TO IMPLEMENT CHANGES (changes to UW policy &
procedure approved & published)
 DEC 26 FEDERAL IMPLEMENTATION BEGINS
University of Washington
Presenter’s Office
Uniform Guidance Working Group
 We established a web page for the team at:
 http://www.washington.edu/research/topics/uniformgrant-guidance/
 Contains links to the Final Uniform Guidance document
 Links to other documents and presentations
 Continues to be updated as more information becomes
available.
Uniform Guidance Working Group
 There are Open Issues…
 Agency deviations – how will these be policed?
 Conflict of Interest – agency plans are key
 Research Terms and Conditions – (FDP) a lot to do in little
time
 Internal Controls – audit repercussions, if any?
 Procurement – could be most significant new burden
 Subrecipient Monitoring – could be second most significant
 Closeouts – not a major change in the Uniform Guidance, but
the pressure for timely closeouts has raised profile
Uniform Guidance Working Group
 Other Issues…
 The UW is working with the Council on Governmental
Relations to obtain clarification from OMB on a number of
areas:




Conflict of Interest – Institutional or individual
Program Income – Treatment of Royalties or other IP Income
Equipment – “Conditional Title”
Procurement – Small purchase threshold – required competition
Uniform Guidance Working Group
 Challenges:
 Conflicting Priorities for team members
 Differing interpretations
 OMB/COFAR slow response to questions
 Pending clarification issues
 Agency implementation plans not published
Uniform Guidance Working Group
 A lot of questions remain but some of the more visible
changes will have little impact on our policy and procedure.
 Effort Certification – No change planned
 Direct Charging of Administrative & Clerical Salaries – Little
or no change planned
 Electronic Records – Already moving to a paperless
environment
 Subrecipient Monitoring – Just revamped our processes
Uniform Guidance Implementation
University of Washington
 Questions?