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

controls references to internal

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