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© 2014 University of New Hampshire. All rights reserved. Uniform Guidance Highlights What you really need to know.

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1 © 2014 University of New Hampshire. All rights reserved. Uniform Guidance Highlights What you really need to know

2 © 2014 University of New Hampshire. All rights reserved. Uniform Guidance (UG)  OMB’s consolidation of circulars for costing, administration and audit of Federal awards  2 CFR 200 replaces 8 circulars and applies to universities, state and local governments, nonprofits, native tribes  Effective largely on December 26, 2014  Each Federal agency will implement a slightly different version of the UG  UG is still being interpreted and clarified

3 © 2014 University of New Hampshire. All rights reserved. Administrative and Clerical Salaries  No real material changes  Generally expected to be paid from indirect costs  However, these costs may be direct charged when: Administrative or clerical services are “integral” to the project Individual is specifically identified Included in sponsor approved budget or other written approval Not also included as indirect cost

4 © 2014 University of New Hampshire. All rights reserved. Participant Support Costs  Includes stipends, subsistence allowances, travel allowances and registration fees  Must be explicitly included in your budget and excluded from the Modified Total Direct Cost (MTDC) base for calculating Facilities & Administrative (F&A) costs.  Added burden of getting prior approval to transfer funds into or out of participant support costs.

5 © 2014 University of New Hampshire. All rights reserved. Computing Devices  Computer devices under $5K can be direct charged if – They are “essential” and allocable to the project  Necessary to acquire, store, analyze, process, and publish data and other information electronically  Project does not have reasonable access to other devices or equipment that can achieve the same purpose  Can’t be direct charged simply for convenience or preference  Machines over $5K are equipment

6 © 2014 University of New Hampshire. All rights reserved. Short-term Visa Costs  Short-term travel visa costs can be direct charged if clearly identified directly connected to work  Usually used for field work in foreign locations or foreign visitors to campus  Does not include costs for long-term, employment- related visas (e.g., J and H1-B visas)

7 © 2014 University of New Hampshire. All rights reserved. Subawards  More prescriptive requirements  Perform a risk assessment of the subrecipient  Subaward vs. Vendor  Establish a monitoring plan for the subrecipient  Financial review  Programmatic review!  Must use subrecipient’s negotiated F&A rate or provide a 10% MTDC “de minimis” rate  No fixed price awards permitted over $150K  Prior agency approval required for fixed price subawards

8 © 2014 University of New Hampshire. All rights reserved. Post Award  Internal Controls – requires us to have strong, internal controls.  No More than $5K in materials remaining at the end of the grant. Implies closer scrutiny on overall spending in the last few months of the award – may need closer monitoring  More emphasis on closeout “no later than 90 calendar days after the end date of the period of performance.”

9 © 2014 University of New Hampshire. All rights reserved. Purchasing  All procurement between the micro-purchase level ($3K) and the Simplified Acquisition Threshold ($150K) must be competitive – for UNH ($3K - $35K)  We do have some time – non federal entities will be given up to one full fiscal year after the effective date of the Uniform Guidance – for UNH – July 1, 2016.

10 © 2014 University of New Hampshire. All rights reserved. Summary  Start using the Uniform Guidance for federal proposal budget submissions.  The cost principles from OMB Circular A-21 have not changed.  The rules governing the charging of administrative and clerical staff salaries have not materially changed, but must be explicitly included in your budget.  Computing devices can be charged as supplies, but the rules governing their allowability and allocability have not changed.  Participant support costs must be explicitly included in your budget and excluded from the Modified Total Direct Cost (MTDC) base for calculating Facilities & Administrative (F&A) costs.  Subrecipients may use an F&A rate of 10% MTDC if they do not already have a Federally approved F&A rate.  The effective date of the rules regarding procurement has been delayed to July 1,  There will be more to come as Federal agencies implement the Uniform Guidance.


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