Uniform Guidance - University of New Hampshire

Uniform Guidance
University of New Hampshire
Uniform Guidance Team
Jan Nisbet, Project Sponsor, Senior Vice Provost for Research
David Browning, Project Manager, Financial Research Administration, SPA
Jo Beth Dudley, Director of Finance and Administration, EOS
Vicki Escalera, Director of Internal Audit, USNH
Louise Griffin, Director of Administration, SVPR
Nancy Hamer, Director of Administration and Financial Services, AA
Karen Jensen, Manager, Research Administration, SPA
Carol Mitchell, Controller, USNH
Francine Ndayisaba, Accounting Manager, USNH
Lisa Pollard, Purchasing Manager, USNH
Kate Roberts, Director of Financial Services, CEPS
Kerry Scala, Finance Director, VPFA Office
Denise Smith, Director of Purchasing, USNH
Victor Sosa, Director, Sponsored Programs Administration
Scott Towle, Manager Cost Analysis, VPFA Office
What is Uniform Guidance
Uniform Guidance (UG) is a
combined, simplified,
version of 8 circulars.
Replaces Existing
Applies to:
Institutions of
Higher Ed (IHE)
All included in 2 CFR 200
Tribal Nations
Effective Date:
Guidance for Federal and NonFederal Entities that applies to:
Co-op Agreements
*Federal contracts follow the FAR,
plus UG for cost principles.
Uniform Guidance Themes
Making the most efficient use of federal funds
More flexibility in the direct cost category, as long as
purchases meet the same direct cost standard (allowable,
allocable and reasonable) and follow Internal Controls
Internal Controls references throughout the document; require
clear roles and responsibilities; and monitoring to ensure
Not new BUT more pressure from agencies for 90 day close
Subawards will need to close in 45 – 60 days
Only NSF has issued implementation guidelines, other agencies
yet to weigh in
The Good, The Bad and the ???
What the guidance is and
what (we think) it means
Much depends on the
agency implementations,
which with the exception
of NSF, remain unknown.
Pre-Award – Good!!!
 Standard Information
 Funding Opportunities need to include standard info – not a change
but good to know
 Prescribed Elements
 Prescribed format, review criteria, cost share requirements, due
dates, deviations in standard terms and conditions, additional
 60 Days Lead Time
 Generally, 60 days lead time for funding announcements, unless
shorter notice is specifically approved by agency head – minimum
of 30 days lead time.
Pre-Award – Good!
Pre-Approved Terms & Conditions
 Agencies must use pre-approved terms and conditions, or
describe deviations at proposal stage
Approval of Exceptions
 Any exception to terms and conditions (e.g., limits on F&A)
must be approved by the agency head and posted on the OMB
Tracking of Exceptions
 OMB will be tracking exceptions to policies, evaluating the
effectiveness of the UG through metrics
Subrecipient Monitoring – Do you want
to hear the good news first?
F&A Improvement
F&A rate agreement must be
honored if one exists
Subrecipient (e.g., foreign, small
businesses, etc.) without a
negotiated rate can get an
automatic 10% MTDC F&A rate.
Increased burden for vendor vs.
subrecipient classification
Prime recipient makes the determination
between Subrecipient vs. Professional
Services/Vendor and we need to
document how we make the decision
each time
Fixed Price Sub Awards
Agency must grant prior approval for
issuing fixed price subawards
New maximum limit for fixed price
subawards $150K
Potentially more risk assessment burden
for OSP as audit threshold increases to
$750K, time will tell
Subrecipient Monitoring ‐ +/‐
Fully documented risk
assessment for each sub prior
to issuance.
New obligation to be able
to prove that UNH (the PI!)
received and reviewed the
subrecipient’s performance
and financial reports
Cost Share – All Good!
Voluntary committed cost sharing is NOT
expected, could be basis for exclusion (NSF)
Cost sharing requirements must be included in the
funding announcement
Cost sharing may not be used as a factor in
reviewing proposals or as merit criteria
Changes in F&A Cost Rulings - Good
Federal agencies are expected to honor
negotiated F&A Rates
Participant Support Costs
Must be excluded from F&A
(similar to NSF Model)
Class or single award exceptions only when
required by Federal statue or regulation, or
approved by an agency head or delegate
Exceptions must be reported to OMB
Policies, procedures and general decision
making criteria for making exceptions must be
Award Notices – Good!
All federal awards must include clear
terms and conditions (for the entire
award period), including:
Reporting requirements
Due Date
Any deviations from agency policy
Provide a basis for objecting when
agency layers on additional
requirements (e.g., prior approvals,
reporting) during the life of an award
Award Terms – More Good!
Recognition that technology allows a PI to be away
from campus and still be engaged in the project
“Disengagement” from the project for more than
three months, rather than “absence” from the
Document Retention - Good!
200.335 – Electronic Record states that there is
no need to create a paper record for a record
that was originally electronic and cannot be
May convert paper to electronic, provided the
records are:
1. Subject to periodic quality control reviews
2. Provide reasonable safeguards against
alteration, and
3. Remain Readable
Still a conflict between UG and FAR which states
that paper records must be kept for a year after
paper records are converted to an electronic
Direct Costs – Good!
Publication Costs (Page Charges)
Page charges are still allowable costs
after award end date but before
closeout (in essence, adoption of the
NSF model); costs must be
consistently charged as a direct cost.
Admin and Clerical Salaries
Eliminated “major project”
May be direct charged when services
provided are:
Integral to the award
Specifically identified with the
Included in the budget or have prior
written approval of the Federal
Computing Devices
Considered supply costs (if it’s under
$5K); can be charged as a direct cost
when devices are “essential and
allocable to a project”, but not
“solely dedicated” to the
performance of the award; need
standards for documentation
Other Cost Items
Conference Costs
Travel Costs
 Requires conference hosts to
exercise discretion and judgment to
ensure that conference costs are
appropriate, necessary and managed
in a way that minimizes cost to the
federal award (remember the notion
of waste and abuse)
Temporary dependent care costs above and
beyond regular dependent care that
directly results from travel to conferences,
is allowable provided:
 Cost is direct result of individual’s
travel for the federal award,
 Cost is consistent with non-federal
entity’s travel policy for all travel
(not just sponsored), and
 Cost is only temporary during the
travel period
 ‘As needed, the costs of identifying,
but not providing, locally available
dependent-care resources are
Recruitment Costs
 Clarification is made that now allows
short term travel visas (but not
longer term immigration visas)
University travel policies will be evaluated for current
and future practices, as the Uniform Guidance requires
consistent treatment between federally funded programs
and non-federal programs.
Time & Effort Reporting
Strengthening of Internal Controls
Examples that used to be provided have now been removed.
These prior examples had been interpreted by auditors to be the
The term ‘Effort Reports’ is no longer explicitly mentioned
Note: While the prescriptive language has changed, and examples
removed, there is still a strong focus on accountability and internal
controls regarding compensation on federal awards. UNH will review
the guidance carefully and evaluate current and future processes for
effort reporting.
Purchasing – Some challenges
All procurement between the micro-purchase
level ($3K) and the Simplified Acquisition
Threshold ($150K) must be competitive – how
will we implement?
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.
Also stresses Small and Minority Owned Business
Internal Controls – More Scrutiny
 Requires us to have strong, internal
 Council on Financial Assistance Reform
(COFAR) offers the following source
documents to be used as best practice,
but are not prescriptively required
 “Standards for Internal Control in
the Federal Government” (Green
Book) issued by the Comptroller
 “Internal Control Framework”
issued by the Committee on
Sponsoring Organizations (COSO)
Could lead to:
 Stronger audit scrutiny and
emphasis on documentation!
 Expect efforts to limit cost
transfers and late salary
Spending at the End of Award – More
No more than $5K in materials
remaining at the end of the
Implies closer scrutiny on overall
spending in the last few months of
the award – may need closer
financial monitoring
Performance Reporting
Continued pressure from agencies to relate research progress to
financial information and other “data” (e.g., number of students,
publications, patents)
Guidance provides for research sponsors to use standard Research
Performance Progress Report (RPPR) format – depends on agency
implementation (NSF is on board!)
Financial Reporting – Didn’t see this
New certification for financial reports – statutory penalties for false
I certify to the best of my knowledge and belief that the report is true,
complete, and accurate and the expenditures, disbursements and cash receipts
are for the purposes and objectives set forth in the terms and conditions of the
Federal award. I am aware that any false, fictitious, or fraudulent information,
or the omission of any material fact, may subject me to criminal, civil or
administrative penalties for fraud, false statements, false claims or otherwise.
Closeouts – More Pressure on 90 Days
No change in federal requirements, but agencies are becoming more
All reports are due “no later than 90 calendar days
after the end date of the period of performance”
 Pressure on agencies – memo from OMB July 2012
 New sub-accounting – NSF, NIH, others to come
 No cash draws on awards after 90 days, except in
exceptional cases, as approved by the agency
 Applies to all reports – PIs get ready
 Focus on more timely financial review
Top Issues To Be Aware Of
1.Many good things in the UG
2.Still waiting for agencies to weigh in
3.Documenting and monitoring internal controls –
where we have gaps
4.Price competition is key
5.Closeouts – in 90 days, for real!
Next Steps
• Working group is continuing to determine full implications and impact
of UG
• Web page has been developed and updates will be posted
• http://www.unh.edu/research/2-cfr-200-uniform-guidance
• Training for the UNH community
• Timing is an issue – dependent on agency implementations
• Communicating
• Ideas?
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