UNIFORM GUIDANCE
Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards
Presented by Colleen Ravenfeld
Office of Research Administration
WHAT IS THE UNIFORM GUIDANCE?
The White House Office of Management and Budget (OMB) has
combined 8 federal circulars into a single document known as
Uniform Guidance.
In TJU’s case, the Uniform Guidance supersedes and streamlines
requirements from 3 OMB Circulars.
• A-21 Cost Principles for Educational Institutions
• A-110 Uniform Administrative Requirements
• A-133 Audit Requirements
The Council on Financial Assistance Reform (COFAR) was delegated
the responsibility of developing the Uniform Guidance, with the goal
of reducing administrative burden while improving oversight and
accountability.
WHAT IS THE UNIFORM GUIDANCE?
• Addresses the administration’s goal of a government that is
more efficient, effective and transparent.
• Strengthens requirements for INTERNAL CONTROLS while
providing administrative FLEXIBILITY for non-Federal entities.
• The Uniform Guidance applies to new awards and
incremental funding to existing awards made on or after
12/26/14.
• The Uniform Guidance is located in Title 2 of the CFR, Part 200
(2 CFR 200).
UNIFORM GUIDANCE TIMELINE
December 26, 2013
OMB issued the Uniform Guidance
June 26, 2014
Due date for the Federal agencies to submit
proposed implementation plans to the OMB to allow
for review and public comment
December 26, 2014 Uniform Guidance goes into effect
June 30, 2015
End of Jefferson’s first fiscal year under the new
Uniform Guidance
July 1, 2015
Uniform Guidance Audit Requirements are
applicable to Jefferson awards
July 1, 2016
Changes to the Procurement Provisions under
the new Uniform Guidance go into effect
UNIFORM GUIDANCE WORKING GROUP GOALS
1.
2.
3.
Analyze the changes in UG against the requirements in the previous
OMB circulars;
Develop a workplan to ensure a systematic assessment of the scope
of the changes against the current Jefferson policies and operating
guidelines;
Recommend actions needed to conform with implementation by
December 26, 2014
The group sought input of Jefferson subject matter experts, including
representatives from:
Audit
Finance
Enterprise Risk
Research Administration
International Office
Human Resources
Office of Legal Counsel
Provost’s Office
Supply Chain Management
Innovation Pillar Leaders
RACE
Compliance
Conflict of Interest Office
HOW IT’S ORGANIZED
TITLE
Subpart A
INCLUDES:
Acronyms & Definitions
Sections 0-99
Subpart B
General Provisions
Applicability
Sections 100-113
Subpart C
Sections 200-211
Subpart D
Sections 300-345
Subpart E
Pre-Federal Award
Instructions to the awarding agency (or
Requirements & Contents pass-through entity)
of Federal Awards
Post Federal Award
Requirements Standards
for Financial & Program
Managements
Instructions to the recipient, including
Internal Controls, Cost Sharing, Program
Income, Budget/Program revisions,
Procurement Standards, Subrecipient
Monitoring, Closeout
Cost Principles
Allowability, Prior Approval,
Direct/Indirect classifications, F&A ,
Selected Items of Cost
Audits
Audit requirements
Sections 400-475
Subpart F
Sections 500-521
Appendix I through IX
Applicable appendices include:
• App. I
Full Text of Notice of Funding Opportunity
• App. II
Contract Provisions for Non-Federal Entity Contract s Under
Federal Awards
• App. III Indirect (F&A) Costs Identification and Assignment, and Rate
Determination for Institutions of Higher Education (IHEs)
• App. IX Hospital Costs
NEW TERMS
NEW TERMS
• Computing devices means machines used to acquire, store, analyze,
process, and publish data and other information electronically, including
accessories for printing, transmitting and receiving, or storing electronic
information. (200.20)
• Fixed amount awards means a type of grant agreement under which the
Federal agency or pass-through entity provides a specific level of support
without regard to actual costs incurred under the federal award. (200.45)
• Micro-purchase means a purchase of supplies or services using simplified
acquisition procedures, the aggregate amount of which does not exceed the
micro-purchase threshold, which is currently $3,000. (200.67)
• Participant support costs means direct costs for items such as stipends or
subsistence allowances, travel allowances, and registration fees paid to or
on behalf of participants or trainees (but not employees) in connection with
conferences, or training projects. (200.75)
SIGNIFICANT CHANGES
INTERNAL CONTROLS
Section 200.303
Recipients of federal funding must:
• establish and maintain effective internal controls that provide
reasonable assurance that Jefferson is managing its awards in
compliance with Federal statutes, regulations and the terms and
conditions of the award.
• Evaluate and monitor compliance and take prompt action when
instances of non-compliance are identified
• Take reasonable measures to safeguard protected personally
identifiable information
The UG emphasizes the importance of having documented internal
controls.
COST SHARING
Section 200.306
The UG reinforces the fact that voluntary committed cost sharing is
neither expected nor considered during merit review of the proposal.
Voluntary committed cost sharing is cost sharing that was included
in the proposal but was not a sponsor requirement.
Federal agencies must require mandatory cost sharing or not
consider it at all. It must be clearly defined in the funding
opportunity.
Unrecovered indirect costs (including indirects on cost sharing) may
be considered cost sharing only with agency prior approval.
The UG supports Jefferson’s strong discouragement of voluntary
committed cost sharing because of it’s financial and administrative
burden.
REVISION OF BUDGET & PROGRAM PLANS
Section 200.308
The following budget or program deviations require prior approval
from the awarding agency:
• Change in scope or the objective of the program
• Change in a key person specified in the application
• PI disengagement from the project for more than 3 months
or a 25% reduction in time (effort) devoted to the project
• Inclusion of costs that require prior approval
• Transfer of funds budgeted for participant support costs
• Subawarding or contracting work out unless described in the
application and funded
• Changes in the amount of cost sharing provided by the nonfederal entity
PROCUREMENT
Sections 200.317 through 326
The UG provides detailed methods by which institutions should
procure goods and services when funded by a federal award
which includes stricter requirements for sole-source
purchases.
The UG emphasizes the documentation requirements and
internal written procedures for procurement.
The OMB is providing a grace period to comply with these
standards, during which the University will modify or develop
procedures to comply with the UG.
SUBRECIPIENT AND CONTRACTOR DETERMINATIONS
Section 200.330
• Provides a list of characteristics which support classification
as a subrecipient (federal assistance relationship) or a
contractor (procurement relationship)
• “Contractor” replaces “vendor”
• Clarifies that the pass-through entity determines the
classification on a case-by-case basis
REQUIREMENTS FOR PASS-THROUGH ENTITIES
Section 200.331
• Includes a standard list of information that must be included
in all subawards
• Requires institutions to perform a risk assessment of
subrecipients prior to issuing subagreements in order to
determine the appropriate level of monitoring. The UG
provides the critieria for determining risk, which includes
prior experience and audit results
• Requirements for subaward monitoring
REQUIREMENTS FOR PASS-THROUGH ENTITIES
Section 200.331
F&A ON SUBAWARDS:
• Pass through entities are expected to honor a subrecipient’s
negotiated rate agreement
• When a subrecipient has a federally negotiated F&A rate, the
negotiated rate must be included in all proposed subawards
• Guidance clarifies that if a subrecipient does not already possess a
negotiated Indirect Cost Rate, it may apply a de minimus rate of
10%. (see section 200.414) It is not permissible for the PI to force
or entice a proposed sub without a negotiated rate to accept less
than the de minimis rate
ADMINISTRATIVE & CLERICAL SALARIES
Section 200.413
The UG clarifies that the salaries of administrative and clerical
staff should normally be treated as indirect costs. Direct
charging of these salaries can be considered only if ALL of the
following criteria is met:
• Services are INTEGRAL to the project;
• Individual can be specifically identified with the project;
• Cost has been explicitly included in the budget OR have
written prior approval from the awarding agency; and
• Costs are not also recovered as indirect costs
Proposal budget justification should clearly detail the integral
nature of the services to the project.
INDIRECT (F&A) COSTS
Section 200.414
• The negotiated rate must be accepted by all Federal
awarding agencies
COMPENSATION
Section 200.430
Standards of documentation: Salary charges to sponsored projects must be
based on records that accurately reflect the work being performed. Those
records must:
• Be supported by a system of internal control which provides reasonable
assurances that the charges are accurate, allowable and properly allocated
• Be incorporated into our official records
• Encompass both federally funded and all other activities
• Support the distribution of the employees salary among specific activities
While OMB A-21 examples and references to formal effort reporting has been
replaced with new terminology, emphasis has been placed on internal controls.
Jefferson’s current effort reporting system is considered an effective internal
control to ensure that compensation charges to Sponsored Projects are
accurate, allowable and properly allocated and will continue with no material
changes
COMPUTING DEVICES
Section 200.453
• The UG clarifies that computing devices are generally considered
to be “supplies” and can therefore be directly charged to
sponsored projects as long as they are essential and allocable to
the performance of the award.
• No longer need to be “solely dedicated”
• Computing devices costing $5,000 or more must be treated as
equipment.
• The proposal budget justification should clearly explain why the
device is essential to the project.
• NEW FORM! RACE requires for modular budgets or when the need
for a device is identified in the postaward stage.
• Section 200.403 “Factors affecting allowability of costs”
continues to apply.
PUBLICATION AND PRINTING COSTS
Section 200.461
The UG allows for the “cost of publication or sharing of
research results” to be charged to the project even if the
costs were incurred after the end of the performance period--BUT before final financial closeout.
The expense would need to be included on the final
reconciliation.
TRAVEL
Section 200.474
The UG relies on Jefferson’s established travel policy to
determine the allowability of travel costs.
Documentation must justify that participation of the individual
is “necessary” to the federal award.
Expect a comprehensive revision of the travel policy to
coincide with the rollout of the new CONCUR travel approval
system.
HOSPITAL COST PRINCIPLES
Appendix IX to Part 200
• 45 CFR Part 74 Appendix E “Principles for Determining Costs
Applicable to Research and Development Under Grants and
Contracts with Hospitals” remain in effect
• OMB has proposed a review process to consider how best to
update and align those principles with the UG.
SUMMARY OF NEW POLICIES AND REVISIONS
110.23
Costing Guidelines for Sponsored Projects
110.25
Unallowable Costs for Sponsored Projects
110.24
Cost Sharing and Matching Funds for Sponsored Projects
110.09
Status Change for Principal investigators and Key Personnel on
Sponsored Projects
110.01
Authorization for Consultant Services Required Sponsored Projects
110.06
Effort Certification for Exempt University Staff on Sponsored Projects
110.07
Effort Certification for Non-Exempt University Staff and All Hospital
Employees on Sponsored Projects
110.20
Sub-recipient Monitoring on Sponsored Projects
110.21
Program Income
110.22
Principal Investigator Role and Responsibilities for Sponsored Projects
TOOLS – 3 GUIDES
1.) Is it a direct or indirect cost? Clarifies how Jefferson
typically incurs selected items of cost (as either a direct or
indirect cost).
2.) Proposal Guide. Provides detail regarding allowability
for selected items of cost.
3.) What Requires Prior Approval From a Federal Agency?
Provides a comprehensive list of circumstances for which prior
approval is specifically required.