On December 26, 2013, the Office of Management and Budget (OMB) issued the “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards.” Also known as the Uniform Guidance, the Omni-Circular or the Super Circular, the Uniform Guidance consolidates, s eight existing OMB Circulars, including Circulars A-21, A-110 and A-133 which apply to federally funded project at institutions of higher education. The new guidance, which will affect all federal grants and contracts, will generally take effect on December 26, 2014.
Federal agencies are currently developing their implementation plans under this guidance. Some processes, procedures and policies at UNL may require updating based upon these changes. UNL has been working with the other campuses in the University of Nebraska system to review possible changes. We will provide further information on changes as they become known.
Proposals submitted now should start using the Uniform Guidance. The cost principles from OMB Circular A-21 have not changed significantly. The guidance specifically provides rules for Administrative and Clerical Staff, Computing Devices, and Participant Support costs.
As in the past, Administrative and clerical salaries should not be direct charged in most cases to federal grants and contracts. While the rules governing “major project or activity” exceptions have been dropped (see Section F.6 and Exhibit C of A-21), they have been replaced by the following criteria in § 200.413, all of which must be met:
(1) Administrative or clerical services are integral to a project or activity; (2) Individuals involved can be specifically identified with the project or activity; (3) Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and (4) The costs are not also recovered as indirect costs.
Administrative and clerical staff must be essential to the scientific/programmatic conduct of the funded project. And in keeping with the requirement of consistent treatment, the services provided by the administrative and clerical staff charged to a Federal award must be unlike the routine services that are provided by administrative and clerical staff charged to institutional funds.
The guidance added language concerning general purpose computing devices in § 200.94. These are allowable as a direct charge however the same criteria that previously existed under A-21, exists under the Uniform Guidance. The computing device must be: (1) essential for the purposes of carrying out a specific aim of the funded project, (2) above and beyond what is normally provided by the department for academic use, and (3) charged to the grant in some reasonable proportion relative to how much it is used for the funded project. We recommend explicitly addressing these unlike circumstances in your budget justification. In addition, PIs and departments should maintain documentation that describes how the proposed computing device meets the above requirements.
Participant Support costs have changed. Under A-110, the transfer of funds allotted for training allowances (direct payment to trainees) to other categories of expense required prior approval from the Federal awarding agency. While the Uniform Guidance retains this prior approval requirement (see § 200.308), it has changed the terminology to participant support costs, defined as “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” (see § 200.75).
In addition, § 200.456 of the Uniform Guidance now states that participant support costs are allowable with the prior approval of the Federal awarding agency. In other words, we now have the added burden of getting prior approval to transfer funds into the participant support cost line as well as to transfer funds out of the participant support cost line! (Note it is likely your proposal guidelines will state whether participant support costs are allowed under the program to which you are applying.) So be extra sure to explicitly include participant support costs in your budget if you need them or you will be required to get sponsor approval later.
In addition, participant support costs will have to be segregated in a separate sub-project grant (a child WBS number) with a 0% indirect cost rate when they are included as part of an award that is recovering indirect costs.
The regulations covering procurement appear at this time to hold the biggest changes. The Federal government has provided a one full fiscal year grace period to comply with the procurement standards. Per the COFAR 8/29/2014 Frequently Asked Questions: … in light of the new procurement standards, for procurement policies and procedures, for the non-Federal entity’s first full fiscal year that begins on or after December 26, 2014, the non-Federal entity must document whether it is in compliance with the old or new standard, and must meet the documented standard. For example, the first full fiscal year for a non-Federal entity with a June 30th year end would be the year ending June 30, 2016. The Single Audit Compliance Supplement will instruct auditors to review procurement policies and procedures based on the documented standard. For future fiscal years, all non-Federal entities will be required to comply fully with the uniform guidance. UNL has opted to defer implementation of the new procurement standards as indicated in the policy notice found here.
At UNL one change you will see beginning in January 2015 is the frequency of PARs for hourly paid staff. Under A-21 rules, for after-the fact reporting records of payroll charges to federal grants and contracts, we were required to prepare PARs no less frequently than monthly. This requirement has been removed. Beginning in January, we will prepare hourly-paid employees’ PARs 3 times a year to coincide with PARs prepared for faculty and other professional staff.
To provide you with information on these changes, the following resources are provided:
Other Federal Resources
- COFAR’s FAQs on Uniform Guidance (8/29/2014)
- COFAR’s FAQ’s on Uniform Guidance (2/12/2014)
- NSF’s Draft Proposal & Award Policies and Procedures Guide
- COFAR Training Intro (1-27-14)
- COFAR Training Administrative Requirements (1-27-14)
- COFAR Training Cost Principles (1-27-14)
- COFAR Training Audit Requirements (1-27-14)
- Links to the Training Webcast Presentation Slides
COFAR Training Administrative Requirements 1-27-14 Slides COFAR Training Cost Principles 1-27-14 Slides
COFAR Training Audit Requirements 1-27-14 Slides
- COFAR: https://cfo.gov/cofar/