New OMB Guidance

Office of Management and Budget (OMB)

Published December 10, 2014

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

OMB issued final guidance on Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in the Federal Register on Thursday, December 26, 2013.  2 CFR Chapter I, Chapter II, Part 200, et al. (78 FR 78590)

This final guidance supersedes and streamlines requirements from OMB Circulars A-21, A-50, A-87, A-89, A-102, A-110, A-122, and A-133.  The final guidance consolidates the guidance previously contained in the aforementioned citations into a streamlined format that aims to improve both the clarity and accessibility. 

OMB has mandated that the federal award-making agencies submit conforming regulation to them by June 26, 2014, and that the new policies take effect uniformly on December 26, 2014.

A summary of key changes can be seen in the following table.

Change
Action Notes
Administrative Salaries can be charged directly to a federal sponsor when the effort is integral to the project. Propose administrative/clerical salaries that are integral to the project and detail benefit in the budget justification.  If you did not propose administrative/clerical salaries, prior approval is required by the sponsor prior to charging.
Defines computing devices < $5,000 as allowable supplies if they are essential and allocable, however they are not required to be solely dedicated to the project. Propose computing devices that are essential and benefit the project. Best Practice: Describe the benefit in the budget justification.
Cost Sharing on federal proposals will not be a factor during the merit review of a proposal except when allowed in the program announcement. It is strongly discouraged to include voluntary committed cost sharing in proposals, except when it is required by the federal funding agency.  
Individual Memberships are not an allowable direct charge on a federally sponsored project. Do not propose or charge individual memberships (business, technical, professional, or personal).  
Introduces increased subrecipient risk analysis and provides a 10% de minimis indirect cost rate if a subrecipient does not have a negotiated rate. Ensure subrecipient budgets includes their negotiated indirect cost rate. If none exists they may request the de minimis 10% indirect cost rate.  
Recognizes that a PI can be absent from campus and remain engaged in the project. If the PI is disengaged from the project for more than three months prior approval from the sponsor is required. A decrease in effort by 25% or more requires prior sponsor approval.
Publication costs can be charged during the 90 day closeout period. The costs of publication or sharing of research results may be charged even if incurred after the end date of the award before award closeout Contact SPS before the end date of an award if you will have publication costs that will post to a federal award during the 90 day closeout period.
Final Financial billing must be completed and submitted to the sponsor within the 90 day closeout period. The sponsor will discontinue reimbursement for expenditures on 90th day or earlier. Be ready to closeout.  All final expenditures must be processed 45 days after the end date of the award.  

Resources

  1. OMB Website
  2. Federal Register (Web Version)
  3. COFAR - Council on Financial Assistance Reform
  4. COFAR - Frequently Asked Questions for Uniform Guidance at 2 CFR 200 August 29, 2014
  5. COFAR - Frequently Asked Questions for Uniform Guidance at 2 CFR 200 February 12, 2014

Training Resources

On Monday, January 27th, the Council on Financial Assistance Reform (COFAR), held a training webcast for more than 5,000 registered viewers, on the major updates to OMB’s recently reformed guidance on Administrative Requirements, Audit Requirements and Cost Principles for Federal Financial Assistance (2 C.F.R. 200). The presenters provided the public with a comprehensive overview of the guidance, insight into the COFAR’s deliberative process during the two year development process, and addressed frequently asked questions. The Uniform Guidance will be implemented one year from publication on December 26, 2014. OMB and the COFAR will continue to engage Federal and Non-Federal stakeholders over the next year to facilitate a smooth implementation process.

  • COGR - Version 2 - Guide to the Uniform Guidance - September 17, 2014
  • COGR - Version 1 - Guide to the Uniform Guidance - April 17, 2014
  • COGR - Perspective on the OMB Uniform Guidance February 27, 2014
  • COGR - Guest Spearker - Norman Dong February 27, 2014
  • COGR - Preliminary Assessment - January 16, 2014 (OMB Uniform Administrative Requirements)
  • FDP Presentation - Council on Financial Assistance Reform's New Uniform Guidance - January 2014

Other Resources

  • COGR and FDP White Paper on the Uniform Guidance
  • NSF - Draft - Proposal and Award Policies and Procedures Guide effective 12-26-2014, NSF 15-1