Transcript OMB Uniform Guidance Effective December 26, 2014

Uniform Guidance Implementation
 Effective on December 26, 2014.
 Uniform Guidance will apply to new awards and
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incremental funding awarded on or after this date.
Prior awards remain under current guidance.
Continuing discussions regarding incorporating the
clarifications provided in the FAQ’s into the Uniform
Guidance document as technical corrections.
Guidelines due to be issued by Federal agencies regarding
their implementation of the Uniform Guidance prior to
December 26, 2014.
Audit provisions go into effect July 1, 2015 for IU.
Same Cost Principles Apply
 The principles that costs must be allowable, allocable,
and reasonable still apply.
Admin and Clerical Salaries
 The salaries of administrative and clerical staff should
normally be treated as indirect (F&A) costs.
 Direct charging of these costs may be appropriate only
if all of the following conditions are met:
 Administrative and clerical services are integral to a
project or activity;
 Individuals can be specifically identified with the project
or activity;
 Such costs are explicitly included in the budget or have
prior written approval of the Federal awarding agency;
 The costs are not also recovered as indirect costs.
Computing Devices
 Materials and supplies used for the performance of a
Federal award may be charged as direct costs. In the
specific case of computing devices, charging as direct costs
is allowable for devices that are essential and allocable,
but not solely dedicated, to the performance of a Federal
award.
 May also be solely dedicated to performance of award.
 Policy applies to items costing less than $5,000, as items
costing more are classified as capital equipment.
 Justification will need to be provided explaining why device
is essential to the performance of the Federal award.
Cost Sharing
 Under Federal research proposals, voluntary
committed cost sharing is not expected.
 It cannot be used as a factor during the merit review of
applications or proposals, but may be considered if it
is both in accordance with Federal awarding agency
regulations and specified in a notice of funding
opportunity.
 Criteria for considering voluntary committed cost
sharing must be explicitly described in the notice of
funding opportunity.
Subrecipient F&A Rates
 An approved Federally negotiated indirect cost rate
negotiated between the subrecipient and the Federal
government or, if no such rate exists, either a rate
negotiated between the pass-through entity and the
subrecipient, or a de minimis indirect cost rate of 10%
of modified total direct costs (MTDC).
Subrecipient Monitoring
 Risk Assessment: Mandatory to do this, but mechanisms
used are at the discretion of the pass-through entity.
 Mandatory monitoring obligations include:
 pass-through entity’s review of subrecipient technical and
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financial reports;
ensuring timely and appropriate action on deficiencies
detected through audits/on-site reviews; and other means;
issuing a management decision for audit findings;
verifying subrecipient received its mandatory Single Audit if
the entity exceeded the $750,000 threshold for Federal funds
expended in the previous fiscal year;
considering whether monitoring findings require the passthrough entity’s records to be adjusted.
Visa Charges
 Short-term, travel visa costs (as opposed to longer-
term immigration visas) are generally allowable
expenses that may be proposed as a direct cost.
 For these costs to be directly charged to a Federal
award, they must:
 Be critical and necessary for the conduct of the project;
 Be allowable under applicable cost principles;
 Be consistent with the non-federal entity’s cost
accounting practices and non-Federal entity policy; and
 Meet the definition of “direct costs” as described in the
applicable cost principles.
Publication Costs
 The non-Federal entity may charge the Federal award
before closeout for the cost of publication or sharing of
research results if the costs are not incurred during the
period of performance of the Federal award.
Temporary Dependent Care
 Temporary dependent care costs above and beyond regular
dependent care costs that directly results from travel to
conferences is allowable provided that:
 The costs are a direct result of the individuals travel for the
Federal award;
 The costs are consistent with the non-Federal entity’s
documented travel policy for all entity travel; and
 Are only temporary during the travel period.
 Due to the requirement for consistency across all
entity travel, IU will not allow direct charging of these
expenses at this time.
2015 and Beyond
 Procurement – grace period for implementation of
procurement regulations until July 1, 2016 for IU.
 Compensation – Personal Services – possible changes
in effort reporting and…
 Internal Controls – Uniform Guidance emphasizes the
importance of Internal Controls.
 More…
Questions?