UNIFORM GUIDANCE OVERVIEW

OMB Circulars Before and After A-21 Cost principles for Educational Institutions A-110 Uniform Administrative Requirements for

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

A-133 Audits of States, Local Gov’ts and non-profit Organizations

A-87 Cost Principles for State, Local and Indian Trial Governments

A-122 Cost Principles for Non-Profit Organizations

A-89 Catalog of Federal Domestic Assistance A-102 Grants and Cooperative Agreements

with State and Local Governments A-50 Audit Followup

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Important Dates

Applicable to new awards and new funding increments issued on and after December 26, 2014

UG is actually guidance to agencies and each agency must submit a draft implementation by June 26, 2014

We expect to see Final Agency implementations some time before or on December 26

Project will not be “done” by December 26, agency implementations and further OMB clarifications will necessitate further review and changes

Issues of Interest

200.112 Conflict of Interest. This is new section and it is not clear if this means investigator COI or Purchasing COI

200.307 Program Income. Not clear how this relates to royalty income

200.317 – 326 Procurement Standards. It is unclear what type of documentation will be necessary for purchases between $3,001 and $150,000

200.303 Internal Controls. Many references to internal controls

Issues of Interest

200.313 Equipment. New terminology and requirement for additional information in property records

200.330 Subrecipient and contractor determinations. May require documentation of decision to use one or the other

200.331 Requirements for pass-through entities. Requirements for subrecipient monitoring may require additional documentation of risk assessment of each entity, review of financial and programmatic reports, audit follow up

Issues of Interest

200.343 Closeouts. Concern that there will be less flexibility in meeting the 90 day closeout requirement

200.419 Cost accounting standards and disclosure statement. CAS still applies.

Prior approval. Many references to written prior agency approval

Note: Some active awards will be under old guidance, some under new during a transition period

Positive Changes

200.203 Notice of funding opportunities. Announcements must include certain minimum information and should be available for at least 30 days

200.301 Performance measurement. Clarification received that standard progress reports, such as the RPPR, are acceptable methods to document performance on research awards

200.306 Cost sharing or matching. Voluntary cost sharing committed in the proposal is not expected and cannot be used during merit review

Positive Changes

200.335 Electronic records are acceptable 200.414 Negotiated F&A rate must be used by federal

agencies unless required to do otherwise by statute or regulation or approval of agency head; if the subrecipient has a federally negotiated rate, the sub must include that rate [200.331(a)(4)], if it does not, we may use 10%

Potential Opportunities

200.413 Direct costs. Although salaries of administrative and clerical staff are still normally to be treated as indirect, there is new language that may offer flexibility regarding when it may be appropriate to charge as direct

200.430 Compensation – personal services. New language allows some flexibility in documenting personnel expenses (including faculty)

200.453 Materials and supplies costs, including costs of computing devices. May allow some flexibility to charge computing devices to grants.

University of Kentucky Plan Steering Committee

Eric Monday, Executive VP for Finance for Finance and Administration Lisa Cassis, Interim Vice President for Research Provost Office Representative

Working Group Co-Chaired by Jennifer Miles, Director Sponsored Projects Accounting and Deborah

Davis, Associate VP for Research, Director Office of Sponsored Projects Administration Includes faculty, associate deans for research, center director, college level business

officer, directors of administrative units affected by UG (HR, Purchasing, Risk Management, General Accounting, Legal Counsel, Graduate School, Accounts Payable…..)

And co-chairs are consulting with Subject Matter Experts not on the Working Group

Working Group Responsibilities/Timeline

Compare new and old guidance Identify UK policies and procedures that

comply with old and identify necessary changes

Look for opportunities to be less restrictive

Draft changes to policies and procedures

Prepare education and communication plan to disseminate to campus

Provide education

May 2014 June 2014

June 2014

July – September 2014

September - October 2014

October – December 2014

Communication/Feedback

Town Hall general campus briefings Faculty meetings Webinars sponsored by professional groups Provost Budget Officers Existing Listservs Website

Resources/Information

Uniform Guidance Federal Register Announcement http://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/2013-30465.pdf

Chief Financial Officers Council (COFAR) Includes FAQs https://cfo.gov/cofar/

UK Uniform Guidance webpage