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© 2014 University of New Hampshire. All rights reserved. Uniform Guidance Highlights What you really need to know
© 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
© 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
© 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.
© 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
© 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)
© 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
© 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.”
© 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.
© 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, 2016. There will be more to come as Federal agencies implement the Uniform Guidance.
The Uniform Guidance: A Top Ten List
OMB Uniform Guidance 2 CFR Part 200. The final guidance was issued on December 26, 2013 and supersedes and streamlines requirements from OMB Circulars.
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards University Senate Meeting Martha Taylor.
UNIFORM GUIDANCE OVERVIEW December 2014 Update. Important Dates Applicable to new awards and (possibly) new funding increments issued on and after December.
Office of Sponsored Programs- OMB Uniform Guidance October 21, 2015.
SHEILA T. LISCHWE, PH.D. OFFICE OF SPONSORED PROGRAMS UNIFORM GUIDANCE WORKING GROUP Uniform Guidance: What is the Impact at CU?
Fiscal Compliance Corner – Uniform Guidance Update MRAM October 2014 Ted Mordhorst Assistant Director for Post Award Financial Compliance Research Accounting.
The Consolidation of the OMB Circulars: Exploring the “New” Administrative Rules.
Uniform Guidance: Summary of Significant Changes 2 CFR PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL.
Uniform Guidance 2 CFR 200 Nicole Pilman, Uniform Guidance Implementation Coordinator Sue Paulson, Assistant Controller Pamela A. Webb, Associate VP for.
OMB Uniform Guidance Faculty Presentation Chris G. Green, CPA Director, Sponsored Programs.
Introduction to Uniform Guidance Presented to Engineering Research Network – Nov 19, 2014 by Sponsored Programs Accounting.
UNIFORM GUIDANCE OVERVIEW Budget Officers Meeting January 28, 2015.
UNIFORM GUIDANCE Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Presented by Colleen Ravenfeld Office.
OMB Uniform Guidance 2 CFR Part 200 What has changed - What hasn’t What works – What doesn’t March 24, 2015.
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards The OMB SuperCircular Information for FTA Grantees.
Indirect Cost Rates 101 CNCS Uniform Guidance § Indirect Costs.
Fiscal Compliance Corner Recent Happenings, etc. MRAM August 2014 Ted Mordhorst Director for Post Award Financial Compliance Research Accounting & Analysis.
Presented By: NameTitleOffice PresentationTitle NCURA Region V Annual Conference April 21, 2015 Michelle G. Bulls, Director Samuel Ashe, Grants Policy.
AGA East TN Chapter Fall Training Uniform Guidance Ron Maples
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