OMB Uniform Guidance
On December 26, 2013, the Office of Management and Budget (OMB) issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements (Uniform Guidance) which amended 2 CFR Chapters I and II. The Uniform Guidance streamlines and supersedes guidance that was previously contained in eight different OMB Circulars. Included in the new guidance are definitions, uniform administrative requirements (both pre- and post-award), cost principles, and audit requirements. From the university perspective, the Uniform Guidance will supersede OMB Circulars A-110, A-21, and A-133.
Federal agencies are required to implement the regulations by December 26, 2014, and new awards and incremental funding awarded on or after December 26, 2014 will be subject to the new regulations.
Published Agency Uniform Guidance Guidelines
Significant Changes in the Uniform Guidance
Emphasis on internal controls (200.303 and multiple other references) – The UG places more responsibility on grantee institutions to establish processes that provide reasonable assurance regarding the achievement of objectives relating to operations, reporting and compliance. This internal-control-integrated framework is expected to include a control environment, risk assessment, information and communication, control activities and monitoring.
Participant Support Costs (200.68) - Participant support costs are excluded from Modified Total Direct Costs, the base for calculating Facilities and Administrative Costs. "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. Participant support costs have always been excluded from MTDC on NSF budgets, but the exclusion has not been specific in the university's F&A rate agreement.
Cost sharing (200.306a) – Voluntary committed cost sharing is not expected and cannot be used as a factor during the merit review of proposals unless it is both in accordance with the agency's regulations and specified in the notice of funding opportunity. TTU operating policy already discourages voluntary cost sharing.
Procurement (200.320) – Methods of procurement are specified which will require changes in TTU procurement policy and processes. OMB has given a grace period for implementation of the new procurement requirements. TTU plans to have new policies in place by September 1, 2015.
Subawards (200.331) –The Guidance emphasizes the need for awardees to assess risk and to monitor and document the monitoring of subawardees. TTU policies and procedures meet the requirements of the Guidance. When PIs approve invoices for subawardees, they are documenting that they are monitoring the programmatic performance of the subawardee and that the performance is satisfactory.
Clerical and administrative staff (200.413) – Salaries for administrative staff may be direct charged if:
- Services are integral;
- Individuals can be specifically identified with the project;
- Costs are explicitly included in the budget or have the prior written approval of the agency; and
- Costs are not also recovered as indirect costs.
Justification for these costs should be included in proposals immediately. TTU will revise institutional policies and procedures to comply with this change.
Computing devices (200.453(d)) – Computing devices are specifically recognized under supplies and are allowable if essential and allocable, but not solely dedicated, to the performance of the Federal award.
Publication costs (200.461) – Grantees will be able to charge before closeout for the costs of publication or sharing of research results if the costs are not incurred during the period of performance of the Federal award."
The close-out period on federal projects typically ranges from 60 to 90 days. Publication costs incurred during this period can be charged. PIs should coordinate with the Office of Research Accounting.
Short-term visas (200.463) – Short-term travel visa costs (as opposed to longer-term, immigration visas) are generally allowable expenses if critical and necessary for the project.
Frequently Asked Questions
1. What effect will the new regulations have on my existing NSF award?
The new regulations will not affect existing awards unless a new increment is added or a modification is made changing the terms and conditions. For a period of time we will have some awards subject to the old OMB Circulars and some awards subject to the Uniform Guidance.
2. My current project is classified as a major project and I am charging clerical/administrative salaries to it. What changes about how I handle these salaries in the future?
In your next proposal you will need to show that salaries for administrative staff meet the two criteria: services are integral and individuals can be specifically identified with the project. Including the costs with justification in the budget will address the third criteria (approval by the agency). TTU's accounting system will automatically address the fourth criteria above (costs are not recovered as indirect costs). "Integral" here is interpreted to mean essential, vital or fundamental to the project or activity.
3. I need to purchase a laptop for my next project. What will I need to do to comply with the Uniform Guidance?
If the laptop has a cost of less than $5000, you will request it in the supplies category in your proposal budget. If the agency you are applying to has not yet issued implementing regulations, you should make clear in your budget justification that the laptop is essential for the project and will provide substantial benefit to the project even if it is not solely dedicated to the project.
Frequently Asked Questions on the COFAR Website
The Council for Financial Assistance Reform has issued FAQs. While the FAQs are helpful in interpreting the Uniform Guidance, the answers do not have the authority of the regulations. The complete list of questions and answers is linked here: https://cfo.gov/wp-content/uploads/2014/08/2014-08-29-Frequently-Asked-Questions.pdf. One FAQ of particular interest to principal investigators is pasted below.
.400-2 Dual Role of Students and Post-Doctoral Staff-The Uniform Guidance states; "For non-Federal entities that educate and engage students in research, 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." Staff in postdoctoral positions engaged in research, while not generally pursuing an additional degree, are expected to be actively engaged in their training and career development under their research appointments as post-docs. This dual role is critical in order to provide post-docs with sufficient experience and mentoring for them to successfully pursue independent careers in research and related fields.
Does 200.400(f) require recognition of the dual role of postdoctoral staff appointed on research grants as, both trainees and employees, when appointed as a researcher on research grants?
Yes, the Uniform Guidance 200.400(f) requires the recognition of the dual role of all pre- and post-doctoral staff, who are appointed to research positions with the intent that the research experience will further their training and support the development of skills critical to pursue careers as independent investigators or other related careers. Neither pre-docs or post-docs need to be specifically appointed in 'training' positions to require recognition of this dual role. The requirements and expectations of their appointment will support recognition of this dual role per 200.400(f).
This page will be updated as more agency guidelines are published and TTU policies are modified. Questions may be directed to firstname.lastname@example.org