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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).
Beginning July 1, 2015, U-M implemented the Uniform Guidance (UG) for our research administration community and has addressed UG Monitored Costs (previously A-21). Additionally, U-M reports on Federal Awards in Accordance with OMB Uniform Guidance (formerly OMB Circular A-133). See current and past audit reports.
Beginning July 1, 2018, U-M implemented the Uniform Guidance (UG) for procurement transactions.
Scroll down for additional FAQs and resources regarding the Uniform Guidance.
The Uniform Guidance can be found at 2 CFR 200.
The Uniform Guidance, found at 2 CFR 200, applies to federal funding agencies, which are required to issue their own policies and procedures that will govern the awards we receive.
Yes, U-M reports on Federal Awards in Accordance with OMB Uniform Guidance (formerly OMB Circular A-133). See current and past audit reports.
For purchases over $10,000, the procurement services will competitively bid based on the current university policy. (SPG 507.01)
For the agencies that have adopted them, RTCs provide a common set of rules for implementing the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) issued by the U.S. Office of Management and Budget (OMB). The RTCs are maintained on the National Science Foundation (NSF) website:
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.
References and Resources
Questions can be forwarded to your ORSP Project Representative or your Sponsored Programs Finance Customer Service Coordinator.