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What is the Uniform Guidance?
The Uniform Guidance is a set of regulations, located at 2 CFR 200, that consolidates federal guidelines impacting research administration including the former A-110 (Grants and Agreements with Institutions of Higher Education), the former A-21 (Cost Principles for Educational Institutions), and the former A-133 (Audit Requirements).
The university is gradually phasing in Procurement policies which will go into effect July 1, 2017.
Scroll down for additional FAQs and presentations regarding the Uniform Guidance.
Like the old OMB Circulars, the Uniform Guidance applies to federal funding agencies, which are required to issue their own policies and procedures that will govern the awards we receive. As of this writing (March 16, 2015), only a handful of federal agencies -- NSF, NIH, EPA, etc. -- have released updated policies and procedures. As a result, continue to follow the old OMB Circulars until the federal funding agency has published updated policies and procedures.
The Uniformance Guidance Audit Requirements go into effect starting on July 1, 2015
If your funding was issued prior to December 26, 2014, you should follow the old OMB Circulars unless the award has been expressly amended to incorporate the Uniform Guidance. However...
A2: Starting July 1, 2015 ALL federally funded awards will follow the Uniform Guidance, regardless of the date they were issued.
Implementation of the new Uniform Guidance procurement standards has been delayed until July 1, 2017, so for now you may continue to operate under the procurement requirements of OMB Circular A-110.
You may use the University's $10,000 threshold until the new Uniform Guidance procurement standards go into effect on July 1, 2017 (FY 2018). Guidance on how to comply with the new procurement standards will be provided closer to the effective date.
NIH clarified at the January Federal Demonstration Partnership meeting that it will require foreign NIH subrecipients to continue using an F&A rate of 8% of Total Direct Costs minus equipment.
The Federal Research Terms and Conditions (RTCs) are currently being revised and do not apply to awards under the Uniform Guidance.
First, remember that the federal agencies are responsible for implementing the terms and conditions of the Uniform Guidance, so you will need to follow the relevant agency's implementation of the Uniform Guidance. Second, make sure all the conditions above are met. For example, in terms of prior approval, you will need NSF's prior approval if the costs meet the requirements above but were not explicitly in the awarded budget. In the case of NIH, you will not need their prior approval provided the costs meet the requirements above, regardless of whether they were in the awarded budget. Both require PACRF to be submitted.
No. You will continue to need to get ORSP approval before purchasing a computing device on your grant. Think of computing devices like other office supplies (e.g., copies, postage, etc.) The Uniform Guidance requires that, in order to be allowable, the circumstances for charging a computing device to a grant must be unlike the normal circumstances under which project personnel are provided computing devices. In addition, the computing device must be allocable to the funded project and therefore must be charged in accordance with relative benefit received by the project. In other words, you must still split the charge for a computing device amongst the various activities that the device will be used for.
The new definition of Participant Support Costs includes both trainees and participants, regardless of status, but is limited to conferences and training grants. Look to the federal awarding agency for further guidance.
Technically, yes. However, the Uniform Guidance also states that temporary dependent care costs related to travel are only allowable if they are "consistent with [U-M's] documented travel policy for all entity travel." Since U-M does not pay from its institutional funds for such costs, temporary dependent care costs associated with travel cannot be charged to a federal grant either.
Yes, Sponsored Programs will still assume under the Uniform Guidance that any cuts to an award came at the expense of the "old A-21" categories.
No, you will not have to go back to the sponsor to get those costs approved again. However, a PACRF will be required to allocate budget to those categories.
We refer to A-21 costs as UG Monitored Costs.