Uniform Guidance aka “UG”, UniGui HUGE: CSU Harnessing Uniform Guidance Effectively An update for SFSU Faculty and Staff
Uniform Guidance Most significant change in research administration in 50 years
Uniform Guidance Reform History Feb 2012 : Nov. 2009: Advance Executive Notice of Dec 2013 : Order: Proposed Reduce Final Guidance Improper Uniform (public Payments Guidance comments) Feb 2011: Feb 2013: Presidential Notice of Memo: Proposed Reduce Guidance Administrative (public Burden comments) 3
Uniform Guidance Timeline Subpart 12/26/2013 Uniform Guidance published by Office of Management and Budget (OMB) Spring 2014 Federal Demonstration Partnership (FDP) and Council on Governmental Relations (COGR) present issues to OMB 5/9/2014 NSF published Draft Proposal and Award Policies and Procedures Guide (PAPPG) 15-1 6/26/14 Agency draft implementation guidelines due (none other than NSF submitted to date) 2/12/14 and Council on Federal Assistance Reform (COFAR) publish FAQs 8/29/14 12/25/14 Research Terms and Conditions Expire 12/26/14 Agency Implementation Guidelines expected to be published ** COGR and FDP still working in include technical corrections and clarifications to FAQs
Uniform Guidance Goals • Elimination of duplicative or conflicting guidance • Focus on performance over compliance for accountability • Encouraging efficient use of technology and shared services • Provide for consistent and transparent treatment of costs • Limiting allowable costs to make most efficient use of federal resources • Setting standard business processes using data definitions • Strengthening oversight and internal controls • Targeting audit requirements on risk of waste, fraud and abuse.
Uniform Guidance • Use to refer to OMB (Office of Management and Budget) • Circular A-110 • Circular A-21 • Circular A-133 • Now refer to Uniform Guidance: 2 CFR 200, Subparts A-F, Sections 100 through 500 • Over 100 pages long • http://www.ecfr.gov
Big Picture Legislation (Laws- Federal and State) Program and Administrative Regulations (codified regulation such as UG, FAR and specific policy manuals) Award Terms and Conditions (incorporates the terms above)
Uniform Guidance Outline Subpart A- 200.XX Acronyms and Definitions B- 200.1XX General Provisions C- 200.2XX Pre-Award Requirements and Contents of Federal Awards D- 200.3XX Post Federal Award Requirements E- 200.4XX Cost Principles F- 200.5XX Audit Requirements Appendix I Funding Opportunities Appendix II Contract provisions Appendix III Indirect Costs (F&A)
Uniform Guidance Implementation • Applies to new awards and funding increments awarded after December 26 th , 2014 (Happy Holidays!) • New Procurement Standards will be deferred by one year grace period- effective 7/1/2016 • Subpart F (Audit Requirements) will be effective July 1, 2015 for CSU
What has changed? Administrative Salaries Subawards Publication Travel Costs Costs Record Retention Faculty Disengagement Cost Sharing Procurement Conferences Close out Computing Visa Costs Devices
Charging Administrative Salaries What changed in UG? UG 200.413 A-21 Uniform Guidance Major Project Integral to a project or activity Definition of “integral”: in·te·gral ˈ in(t) əɡrəl,inˈteɡrəl / adjective 1 . necessary to make a whole complete; essential or fundamental. Allowable, Allocable, Reasonable….. Still apply!
New Rules for Charging Admin inis istrativ ive Sala laries The salaries of Administrative and Clerical Staff should normally be treated as indirect (F&A) costs Direct Charging of these costs may be appropriate of all of the following conditions are met: • Administrative or clerical services are integral to a project or activity; • Meaning that the services are essential, vital or fundamental to the project • Individuals involved can be specifically identified with the project or activity; • Such costs are explicitly included in the budget or have the prior written approval of the Federal funding agency; • A budget justification must be included in the proposal, • The costs are also not recovered as indirect costs UG 200.413
SFSU Policy • Federal Awards received prior to December 26 th must continue to follow OMB A- 21 Guidance • New Awards will follow the new Uniform Guidance • Non-Federally Sponsored Projects • Direct charging of administrative or clerical salaries to a non-federally sponsored project may be appropriate if the services benefit that sponsored project. • These charges need to be addressed in proposals UG 200.413
Charging Computing Devices What changed in UG? A-21 Uniform Guidance Must be specifically tied to a project Now considered a “supply” Devices under $5,000 equipment threshold Essential and allocable, but not solely dedicated, to the performance of a federal award Allowable, Allocable, Reasonable….. Still apply! UG 200.453
New Rules for Charging Computin ing Devices to UG Sponsored Programs 200.453 • “ Supplies means all tangible property other that those described in Section 200.33. A computing device is a supply if the acquisition cost is less than the lesser of the capitalization level established by the non-Federal entity for financial statement purposes or $5,000 regardless of the length of its useful life. • Computing devices means machines used 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. • 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.
SFSU Policy UG • Federal Awards received prior to December 26 th must continue to follow 200.453 OMB A-21 Guidance • New Awards will follow the new Uniform Guidance • Federal sponsors may impose requirements for these costs to be included in the proposal budget, and may require a justification • PIs will still need to provide a justification for these purchases and describe how these are essential and allocable to the project • Non-Federally Sponsored Projects • Direct charging of computing devices to a non-federally sponsored project may be appropriate if the devices benefit that sponsored project. • These charges need to be addressed in proposals
Charging Visa Costs What changed in UG? A-21 Uniform Guidance No guidance Costs associated with visas when critical skills are needed for a specific award may be proposed and charged as a direct cost Allowable, Allocable, Reasonable….. Still apply! UG 200.463
PI/Project Director Disengagement What changed in UG? UG 200.308 A-21 Uniform Guidance Prior approval required for the absence New language to reflect that PIs/ Project of the approved PI or Project Director for Directors can be away from campus and more than three months remain engaged in the project at the proposed and awarded levels
Prin incipal l In Investigator/Project Dir irector Dis isengagement • For non-construction Federal Awards, recipients must request prior approvals from Federal awarding agencies for one or more of the following program or budget-related reasons: • (1) Change in scope and objective of the project or program (even if there is no associated budget revision requiring prior approval) • (2) Change in a key person identified in the proposal or the award • (3) Disengagement from the project for more than three months, or a 25% reduction in time devoted to the project, by the approved project director or Principal Investigator. UG 200.308
Travel Costs What changed in UG? A-21 Uniform Guidance Airfare costs in excess of the customary 1. Commercial airfare- least expensive standard commercial airfare (coach or unrestricted accommodations UG equivalent), Federal contract airfare 2. Family friendly policy allowing for 200.474 (where authorized and available), or the dependent care under specific and lowest commercial discount airfare are limited circumstances unallowable except…. Under discussion with colleagues in the CSU and the Chancellor’s Office
Travel and Dependent Care Costs • Commercial Airfare: least expensive unrestricted accommodations class offered by commercial airlines • Temporary dependent care costs (dependent defines in 26 U.S.C. 152) above and beyond regular dependent care that directly results from travel to conferences is allowable provided that: (i ) the costs are a direct result of the individual’s travel on the Federal award; (ii) the costs are consistent with the non- Federal entity’s documented travel policy for all entity travel; and (iii) are only temporary during the travel period. • Travel costs for dependents are unallowable, except for travel of duration of six months or more with prior approval of the Federal awarding agency. • See also section 200.432 (Conferences) UG 200.474
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