Transcript Uniform Guidance: What is the Impact at CU? SHEILA T. LISCHWE, PH.D. OFFICE OF SPONSORED PROGRAMS UNIFORM GUIDANCE WORKING GROUP.

Uniform Guidance: What is the
Impact at CU?
SHEILA T. LISCHWE, PH.D.
OFFICE OF SPONSORED PROGRAMS
UNIFORM GUIDANCE WORKING GROUP
What is the Uniform Guidance?
 OMB Initiative to reduce duplication and
administrative burden by combining federal
regulations between 8 OMB circulars into one
“supercircular”
 Governing Body – Council on Financial Assistance
Reform (COFAR)
 Membership includes reps from NSF, NIH and other
major agencies
Motivating Factors
 Federal Demonstration Partnership (FDP) Surveys
– 2007 & 2012
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42 percent of investigator time spent on administration
 National Science Board Report on Reducing
Administrative Burden (2014)
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Roundtables and potential solution
Timeline
 Released December 26, 2013
 Agency implementation plans due to OMB by June
26, 2014
 Regs effective December 26, 2014
 Agency regs released 12/19/14
Overarching Approach
 Reduce administrative burden on investigator
 Ensure against waste, fraud and abuse
 Increased focus on “Internal Controls” within an
institution
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Policies and procedures
Strategies to identify ways to deflect and detect potential abuse
of federal funds
Key Changes
 Administrative support allowable as direct cost with
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prior approval
Computing devices now allowable
Voluntary cost-share prohibited
Full F&A negotiated rate encouraged
Publication Costs allowed after end date
Coverage of short-term visa costs
Administrative Salaries as DC
 “Integral” to the project
 Definition: essential to completeness
 Must be included in proposal budget or have prior
approval from agency
 Named personnel
 CU will require strong budget justification to prove
“integral” nature of position to project
Computing Devices
 Allowable as a direct cost if they are essential and
allocable but not solely dedicated to the
performance of a federal award.
Computing Devices
 What is essential?
 necessary to acquire, store, analyze, process, and publish data
and other information electronically, including accessories (or
“peripherals”) for printing, transmitting and receiving, or
storing electronic information
 no reasonable access to other devices or equipment that can
achieve the same purpose; devices may not be purchased for
reasons of convenience or preference.
 PIs and departments should maintain documentation that
describes how the proposed computing device meets the
above
Voluntary Cost Share/Full F&A
 Cost share cannot be used as a factor in merit review
process
 Full, negotiated rates encouraged
 Agencies can make exceptions to the above if it is
clearly delineated in the solicitation
Publication Costs
 The non-Federal entity may charge the Federal
award before closeout for the costs of publication or
sharing of research results if the costs are not
incurred during the period of performance of the
Federal award.
 May see a cutoff threshold implemented:
e.g. End date + 60 days
BREAKING NEWS: Closeout in 120 days?
Short Term Visa Costs
 Must be for a specific period and purpose
 Typically J-1 and H-1B
 Not allowable:
– premium or expediting processing fees
– renewal application fees
- institutional charge for processing
- dependent application/processing fees
Other Administrative Changes
 Standardization of G.g. forms – no agency-specific
forms allowable without OMB approval
 60 day notice for RFPs
 Fixed Price Subawards up to $150k
 Prior approval for faculty disengagement for three
months or effort reduced by 25%
Challenges
 How will OIG interpret and audit against the new
regs?
 Will operate under 2 sets of regs
 90 day auto closeout
 Measuring Performance
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Progress report reminders & completion assurances
PI Certification
Subrecipient Performance
What is CU doing to prepare?
 UG Working Group
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GCA (post-award)
OSP Pre-Award
HR, Payroll, Compensation
Provost’s Office
Controller’s Office
Internal Audit
Procurement
Faculty Senate/FS Research Committee
CU Preparations
 Critical Issues Template
 What policies/procedures need to change?
 Following Lead of Professional Associations
 Updating OSP Certification Program
 Letter from Provost