Uniform Grant GuidanceHighlights

February 5, 2015

Uniform Grant Guidance(2 CFR, Subtitle A, Chapter II, Part 200 Uniform Administrative Requirements, Cost

Principles and Audit Requirements for Federal Awards)

Better known as the “UGG”

Streamlining was the Goal:Code of Federal Regulations under Title 34-

Education Removed : Part 80 Uniform Requirements for Grants &

Cooperative Agreements to State & Local GovernmentsRemoved: Part 74 Administration of Grants &

Agreements with Institutions of Higher Education, Hospitals & Other Non-Profit Organizations

Updated: Parts 75, 76, 77 & 81 to incorporate the changes.

Streamlined the requirements from a number of OMB Circulars (A-21, A-87, A-110, A-122, A-89, A-102, A-133 and parts of A-50)

http://www.ecfr.gov/cgi-bin/text-idx?SID=50ad1b3d72950e558441b83a7d3baacf&node=pt2.1.200&rgn=div5

Streamlines guidance for Federal awards to ease the administrative burden.

Strengthen oversight of Federal funds to reduce risk of waste, fraud and abuse.

Increased focus on performance outcomes.

Applicable to new awards made after 12/26/14– begins with Perkins 7/1/15

2 CFR Grants and Agreements- Part 200 (UGG)

Highlights:Heavier emphasis on the pass –through

entity (ADE) to monitor performance and not just compliance 200.331(d)

Will continue to be looking at both fiscal and programmatic activities.

Multiple mention of performance, program outcomes and productivity as a major focus area.

Highlights:A non-Federal entity may charge to the

Federal award only allowable costs incurred during the period of performance (unless given special permission for pre -award costs) 200.309.

Period of performance for Perkin’s is generally July 1 through September 30

Cannot obligate (order) in one fiscal year and liquidate (pay) in another.

May have implications for travel and payroll

Highlights:Non-federal entities hosting or sponsoring a

conference may include meals unless further restricted by the conditions of the federal award 200.432.

U.S. Department of Education grants have a very difficult burden to prove the allowability of food.

See specific guidance:“Frequently Asked Questions on Using Funds for Conferences and Meetings” December, 2014

http://www2.ed.gov/policy/fund/guid/gposbul/gposbul.html

Highlights:Time & EffortPreviously (A-87 Circular) required:

Semi-Annual Certifications for employees that work for a single cost objective.

After the fact recording Account for total activity Signed by employee and supervisor Every six months

Personnel Activity Report (PAR) for employees that work on multiple cost objectives.

After the fact recording Account for total activity Signed by employee Prepared at least monthly and coincide with one or

more pay periods.

Highlights:Time & Effort per new UGG Requirements

200.430(i):Less prescriptive rules- significant flexibility in

adopting own processes.Charges accurately reflect work performed.Supported by a system of internal controls

providing assurance charges are accurate, allowable and properly allocated.

Incorporated into the official records Reasonably reflect total activity Encompass all activities (federal and non-federal) Comply with standard accounting practices/policies Able to support distribution among specific activities or

cost objectives.

If current system meets more stringent requirement, recommend maintaining.

Highlights: Procurement Changes

Micro-Purchases 200.320 Acquisition of supplies or services not to exceed

$3,000 Award without competitive quotes Distribute equitably among qualified suppliers

Small Purchase 200.320 Raises the purchase acquisition threshold Goods & Services that cost less than $150,000

NEW

Highlights: Supplies-

Computing Device 200.453 Considered a supply if cost is less than $5,000

regardless of the length of its useful life. Inventory management– regardless of cost, must

maintain effective control and safeguard all assets to ensure they are used for the authorized purpose.

Equipment-Replacement Equipment 200.313(c)(4)

When acquiring replacement equipment, can trade-in or sell the property and use proceeds to offset cost of replacement property.

Highlights:Change to Audit Requirement 200.501

Non-Federal entity that expends $750,000 or more during fiscal year in Federal awards must have a single or program audit.

Reminders:Record Retention Requirements 200.333

Records for Federal awards maintained for three years from the date of approval of the Completion Report

If litigation, claim or an audit is started before three years expires, must continue retention until resolved.

Entertainment Costs 200.438 Unallowable unless have a programmatic purpose and

are authorized in approved budget or prior written approval.

Marilyn GardnerCTE Fiscal Director602-542-5137