Recent Changes Published in
Part 200 Uniform Guidance
-- Cost Principles
Steve Bradley,
Director
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Agenda
– New Structure (“Roadmap”)
• Highlighting relevant F&A and Cost Principle sections
– Costing Principles
• Including eliminations of prior A-21 sections
• MAXIMUS Impact Assessment
– Resources
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Structure (cont.)
– Subpart E – Cost Principles (A-21, A-87, A-122)
• General Provisions
§ 200.400 to 401
• Basic Considerations (Cost
Allowability, Applicable credits)
• Direct and F&A Costs (including
required Certifications)
• State, Local & Indian Govt
§ 200.402 to 411
• Special Considerations for
Institutions of Higher Education
• General Provisions for Selected
Items of Cost (Prior A-21, section J)
§ 200.418 to 419
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§ 200.412 to 415
§ 200.416 to 417
§ 200.420 to 200.475
Structure (cont.)
– Subpart F – Audit Requirements (A-133)
– Appendices (combination of all 8 Circulars)
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I – Notices of Funding
II – Contract Provisions
III -- F&A for Educational Institutions (A-21)
IV – Indirect for Non-Profits (A-122)
V – State/Local Cost Allocation Plans (A-87)
VI – Public Assistance (A-87)
VII – State/Local Indirect Cost Plans (A-87)
VIII – Non-Profit Exemption from Cost Principles (A-21)
IX – Hospitals (TBD)
X – Audit Data Collection (A-133)
XI – Single Audit Compliance Supplement (A-133)
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OMB Changes – Combine Circulars
• Consolidate A-87, A-21 and
A-122 Cost Principles
• Create a common
accounting standards for
all grant recipients
IMPACT
--Probably add more
confusion than clarity
--Universities are much
different than Nonprofits and State/Local
Govt’s
--Document littered with
“exceptions” (e.g., A-21
26% Admin cap )
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OMB Changes – Flat Rate
• For F&A costs, use a flat rate
instead of current negotiated
rate system – NOT in new
guidance
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IMPACT
GREAT!
•Flat / “tiered” rate
idea was not well
received and has been
dropped
OMB Changes – UCA (App. III B.4.c)
•
•
•
Maximum 1.3 Utility Cost
Adjustment with “Utilities”
allocations based on “Effective
square footage”
ESF is actual SF times “Relative
Energy Utilization Index (REUI)
• REUI is currently 2X
• OMB will adjust factor “no
more often than annually nor
less often than every 5 years”
Allows metering at a Sub-Building
level????
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IMPACT
GREAT (for some)!
Increase burden (for
others)!
•Perhaps a Double-Edged
Sword?
•Schools will now have to
develop data for their
Utilities pools
•“Separate Proposal”
OMB Changes – Eliminate Required Study
• Eliminate requirement for
institutions to conduct studies
for cost reasonableness for
Large Research Facilities
• prior A-21, F2
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IMPACT
--GREAT!
--Reduce
administrative burden
OMB Changes – Eliminate Mandated F&A Usage
IMPACT
•
Eliminate requirement that
certain institutions must use
F&A recoveries associated
with depreciation to acquire
or renovate research
buildings or equipment
•
prior A-21, J14h
•
Currently applies to 99
schools
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--GREAT!
--Reduce
administrative burden
OMB Changes – Eliminate Required Analysis
• Eliminate requirement that
schools perform a Lease
Purchase Analysis to justify
External Bond Interest
• prior A-21, J26
IMPACT
--GREAT!
--Reduce
administrative burden
--But, Retained “25%
Equity Contribution”
rule
• now Subpart E, 200.449
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OMB Changes – DS-2 (Subpart E, 200.419)
• Disclosure Statements (DS2) & Compliance under the
Cost Accounting Standards
Board (CASB), retained
(prior A-21, C14)
• Threshold raised from $25M
to $50M
• Added: University proposed
change must be submitted to
DCA/ONR 6 months in
advance
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IMPACT
--Reduce
administrative burden?
Change in effect next
FY unless hear from
DCA/ONR
OMB Changes – 10% Rate for First-timers
• Addition of 10% deminimus indirect cost rate
(modified total direct cost
basis) for entities that do not
currently have a negotiated
rate
• Subpart E, 200.414
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IMPACT
GREAT!
--May reduce the need
for university staff to
review indirect
proposals from these
type sub awardees /
subcontractors
OMB Changes – Cost Sharing
•
Affirm that Voluntary
Committed Cost Sharing is
NOT expected & is NOT to be
used as a factor in review of
applications
•
Subpart D, 200.306
•
Only mandatory cost sharing
and cost sharing specifically
committed in the project
budget must be included in the
organized research base
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IMPACT
GREAT!
--Probably reduce
administrative burden
and/or Organized
Research “base”
--VUCS clarification
still in effect
OMB Changes – Direct Charging of Admin.
•
Salaries of administrative staff
may be direct charged to federal
grants where ALL of the following
are met:
• Services are integral to the
project
• Individuals can be specifically
identified to the project
• Explicitly included in the
budget or have prior written
approval
• AND, are not recovered as
indirect costs
• Subchapter E, 200.413
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IMPACT
DOUBLE-EDGED SWORD!
--May reduce confusion
--But may increase the
Organized Research
MTDC base and, in turn,
lower proposed rates
--As offset, F&A rates
would be applied to these
new direct costs, increasing
F&A Dollar Recoveries
OMB Changes – Rate for All Agencies
• IMPACT
• Require Federal agencies to
accept negotiated indirect
(F&A) cost rates, unless an
exception is required by
statute or regulation; and,
Federal agency must notify
OMB of any approved
deviations
• Subpart E, 200.414
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• Regrettably, not much
change
• Except, OMB will now
have central repository of
these
• For example, USDA,
8% Training grants, etc.,
will probably stay at
reduced F&A rates
OMB Changes – Effort Certification
IMPACT
•
Remove the “Examples of
Acceptable Methods for Effort
Certification for Payroll
Distribution”
•
Emphasis on “Internal
Controls” and “Performance”
•
prior A-21, section J10
•
Subpart E, 200.430
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•Reduces Effort
Certification burden
•Allows “flexibility in how
universities can meet
standards”
•“Final guidance does not
require current
PAR’s/similar
documentation”
•Also, FDP doing their own
“Project Certification”
Demo, including reviews by
OIG’s
OMB Changes – Rate Extension
•IMPACT
• All Non-Federal entities may
apply for a one-time
extension of current F&A
rates for up to four years,
subject to cognizant agency
approval
• Subpart E, 200.414
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•May be appropriate for
some universities
•For others, may reduce
F&A dollar Recoveries
(e.g., if major new
research buildings, if
now eligible for UCA,
or substantial decrease
in base re: end of ARRA
grants)
OMB Changes – Computing Devices
IMPACT
• Addition of new language
which allows “Computing
devices” and associated
support costs to be treated as
allowable and allocable direct
costs
• Subpart E, 200.453
DOUBLE-EDGED SWORD!
•May reduce confusion
•But may increase the
Organized Research
MTDC base and, in turn,
lower proposed rates
•As offset, F&A rates would
be applied to these new
direct costs, increasing F&A
Dollar Recoveries
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OMB Changes – MTDC (App. III C.2)
• App. III C.2. references
section 200.68 where
participant support costs,
defined in 200.75, are listed
as an exclusion to MTDC
• Other items may only be
excluded when necessary to
avoid a serious inequity in
distribution of indirect costs,
and with the approval of the
cognizant agency
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IMPACT
-- Perhaps increase
burden to identify new
exclusion
-- Possibly deter
agencies adding unfair
base exclusions (e.g.
genomic arrays)
OMB Changes – Library Expenses (App. III B.8)
• The professional employee
category can include postdoctorate fellows and
graduate students
• The other users category can
be based on a reasonable
factor as determined by
institutional records to
account for all other users of
library facilities
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IMPACT
--GREAT!
--Support standard
practice allocation to
postdocs and grad
students
--Reduce
administrative
burden
OMB Changes – Dual Role of Students
•
•
Kept language stating “ …
the dual role of students as
both trainees and employees
contributing to the completion
of Federal awards for
research must be recognized
in the application of these
principles.”
Subpart E, 200.400(f)
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IMPACT
--GREAT!
--May have reduced
F&A rates if omitted
Unresolved Issues
• When will revised DCA Best Practices Manual be
published?
• UCA for FY14 base year F&A rate proposals?
• Definition of “monitored research laboratory space”
re: UCA
• Format for “separate calculation proposal” for UCA
• Does “one time” extension mean once in the life of
the rate or once in the life of the institution
• Send questions to COFAR cofar@omb.eop.gov
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Resources
http://www.maximus.com/our-services/education/highereducation/omb-uniform-guidance
• Federal Register article: Web | PDF
• 2 CFR Part 200: eCFR - Code of Federal Regulations
• The OMB website includes many helpful links:
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OMB Policy Statements: Uniform Grant Guidance
Crosswalk from Existing Guidance to Final Guidance
Crosswalk from Final Guidance to Existing Guidance
Cost Principles Comparison Chart
Audit Requirements Comparison Chart
Definitions Comparison Chart
Administrative Requirements Comparison Chart
COFAR
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Contact Us
Email: highereducationinfo@maximus.com
Telephone: 800-709-2747
Website: http://HigherEducation.MAXIMUS.com
Facebook: MaximusHEP
Twitter: #MaximusHigherEd
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