Uniform Guidance Highlights
What you really need
to know
© 2014 University of New Hampshire. All rights reserved.
Uniform Guidance (UG)
 OMB’s consolidation of circulars for costing, administration
and audit of Federal awards
 2 CFR 200 replaces 8 circulars and applies to universities,
state and local governments, nonprofits, native tribes
 Effective largely on December 26, 2014
 Each Federal agency will implement a slightly different version
of the UG
 UG is still being interpreted and clarified
© 2014 University of New Hampshire. All rights reserved.
Administrative and Clerical
Salaries
 No real material changes
 Generally expected to be paid from indirect costs
 However, these costs may be direct charged when:
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Administrative or clerical services are “integral” to the
project
Individual is specifically identified
Included in sponsor approved budget or other written approval
Not also included as indirect cost
© 2014 University of New Hampshire. All rights reserved.
Participant Support Costs
 Includes stipends, subsistence allowances, travel
allowances and registration fees
 Must be explicitly included in your budget and
excluded from the Modified Total Direct Cost
(MTDC) base for calculating Facilities &
Administrative (F&A) costs.
 Added burden of getting prior approval to transfer
funds into or out of participant support costs.
© 2014 University of New Hampshire. All rights reserved.
Computing Devices
 Computer devices under $5K can be direct charged if –
They are “essential” and allocable to the project
 Necessary to acquire, store, analyze, process, and publish
data and other information electronically
 Project does not have reasonable access to other
devices or equipment that can achieve the same purpose
 Can’t be direct charged simply for convenience or preference
 • Machines over $5K are equipment
© 2014 University of New Hampshire. All rights reserved.
Short-term Visa Costs
 Short-term travel visa costs can be direct charged if
• clearly identified
• directly connected to work
 Usually used for field work in foreign locations or
foreign visitors to campus
 Does not include costs for long-term, employmentrelated visas (e.g., J and H1-B visas)
© 2014 University of New Hampshire. All rights reserved.
Subawards
 More prescriptive requirements
 Perform a risk assessment of the subrecipient
 Subaward vs. Vendor
 Establish a monitoring plan for the subrecipient
 Financial review
 Programmatic review!
 Must use subrecipient’s negotiated F&A rate or provide a 10%
MTDC “de minimis” rate
 No fixed price awards permitted over $150K
 Prior agency approval required for fixed price subawards
© 2014 University of New Hampshire. All rights reserved.
Post Award
 Internal Controls – requires us to have strong, internal
controls.
 No More than $5K in materials remaining at the end of the
grant. Implies closer scrutiny on overall spending in the
last few months of the award – may need closer monitoring
 More emphasis on closeout “no later than 90 calendar
days after the end date of the period of performance.”
© 2014 University of New Hampshire. All rights reserved.
Purchasing
 All procurement between the micro-purchase level
($3K) and the Simplified Acquisition Threshold
($150K) must be competitive – for UNH ($3K $35K)
 We do have some time – non federal entities will be
given up to one full fiscal year after the effective
date of the Uniform Guidance – for UNH – July 1,
2016.
© 2014 University of New Hampshire. All rights reserved.
Summary
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Start using the Uniform Guidance for federal proposal budget submissions.
The cost principles from OMB Circular A-21 have not changed.
The rules governing the charging of administrative and clerical staff salaries
have not materially changed, but must be explicitly included in your budget.
Computing devices can be charged as supplies, but the rules governing
their allowability and allocability have not changed.
Participant support costs must be explicitly included in your budget and
excluded from the Modified Total Direct Cost (MTDC) base for calculating
Facilities & Administrative (F&A) costs.
Subrecipients may use an F&A rate of 10% MTDC if they do not already
have a Federally approved F&A rate.
The effective date of the rules regarding procurement has been delayed to
July 1, 2016.
There will be more to come as Federal agencies implement the Uniform
Guidance.
© 2014 University of New Hampshire. All rights reserved.