The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) was issued by the Office of Management and Budget on December 26, 2013. The Uniform Guidance is intended to serve as a single place where all the regulations applicable to federal awards can be found. The Uniform Guidance replaces the long-standing OMB Circulars A-21, A-110 and A-133. Each federal agency is also in the process of finalizing their implementation of this new guidance.
This document highlights some of the more significant changes that may impact your new grant applications, or new awards or funded increments received on or after December 26, 2014. For a while, you may have grants under two different sets of regulations.
Per the Uniform Guidance, the purchase of computers on federal awards is considered a supply item, and is allowable when the acquisition cost is under $5,000. Computers should be essential to carrying out the specific aim of the project, and charged to the grant in a reasonable proportion relative to how much it is used on the grant. Computing equipment costing $5,000 or more falls into one of two categories: general purpose or special purpose and will follow federal equipment rules for when it can be direct charged.
Federal agencies must post funding opportunities at least 60 days prior to a deadline.
If a subrecipient has a negotiated F&A rate it must be used. Subrecipients can now receive a de minimis F&A rate of 10% if they do not have a federally negotiated F&A rate of their own.
Participant support costs are allowable on sponsored projects if the project includes an educational or outreach component. These costs must be separately budgeted and approved by the sponsor. Under the new guidance participant support costs are exempt from F&A for all sponsors.
Prior approval is required for the PIs disengagement from the project for more than 3 months, however being away from campus does not necessarily constitute disengagement.
The Uniform Guidance requires that all financial, performance and other reports be submitted no later than 90 days after the end date of the award. Some agencies have extended this to 120 days.
The Uniform Guidance imposes new limits on agencies’ ability to solicit cost sharing:
With prior written approval from the sponsor, Baylor may make subawards based on fixed amounts up to $150,000.
The new procurement regulations have been some of the broadest and most far-reaching of the Uniform Guidance. New requirements for documentation of competition are dependent on purchase price:
Publication costs are allowable during the project, and after the project end date, but before closeout.
Institutions continue to be required to perform a risk assessment of subrecipients prior to issuing the subaward to determine the appropriate level of monitoring. There will be a stronger tie of payment to performance and we will work with PIs to determine how to best coordinate requirements for monitoring subrecipients’ performance.
Travel must not exceed the basic least expensive unrestricted airfare, rather than the prior lowest commercial discount fare (basic = coach, economy or equivalent).
Costs associated with visas when critical skills are needed for the specific award may be proposed and charged as direct costs.
Please Contact your OSP coordinator with questions.