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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.
Documentation Transactions posted to sponsored funds Sponsored Programs Administration October 2012.
SHEILA T. LISCHWE, PH.D. OFFICE OF SPONSORED PROGRAMS UNIFORM GUIDANCE WORKING GROUP Uniform Guidance: What is the Impact at CU?
A DEEPER LOOK INTO THE CHANGES TO COME Presented by: Susan Cessac, Manager of Cost Analysis Heather Dempsey, Senior Accountant – Cost Analysis University.
OMB Uniform Guidance 2 CFR Part 200. The final guidance was issued on December 26, 2013 and supersedes and streamlines requirements from OMB Circulars.
OMB Uniform Guidance 2 CFR Part 200 What has changed - What hasn’t What works – What doesn’t March 24, 2015.
Fiscal Compliance Corner Recent Happenings, etc. MRAM August 2014 Ted Mordhorst Director for Post Award Financial Compliance Research Accounting & Analysis.
2014 TAACCCT TRAINING AND CONVENING Allowable Costs.
The Uniform Guidance: A Top Ten List
Introduction to Uniform Guidance Presented to Engineering Research Network – Nov 19, 2014 by Sponsored Programs Accounting.
OMB Uniform Guidance Faculty Presentation Chris G. Green, CPA Director, Sponsored Programs.
UNIFORM GUIDANCE Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Presented by Colleen Ravenfeld Office.
New Uniform Guidance Combines the requirements of OMB Circulars A-21, A-87, A-110, A-122, A-89, A-102, A-133, and A-50 into a streamlined format. *NOTE:
Grants Administration Updates - OMB’s Uniform Guidance Division of Grants Administration Office for Grants and Federal Fiscal Compliance Texas Education.
University of New Hampshire
Grant Guidance Changes
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards University Senate Meeting Martha Taylor.
Uniform Guidance April 21, 2014 Sara Bible Office of the Vice Provost and Dean of Research.
Subawards and Subrecipient Monitoring
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.
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