Presentation on theme: "University of New Hampshire"— Presentation transcript:
1 University of New Hampshire Uniform Guidance (UG!)University of New Hampshire
2 Uniform Guidance TeamJan Nisbet, Project Sponsor, Senior Vice Provost for ResearchDavid Browning, Project Manager, Financial Research Administration, SPAJo Beth Dudley, Director of Finance and Administration, EOSVicki Escalera, Director of Internal Audit, USNHLouise Griffin, Director of Administration, SVPRNancy Hamer, Director of Administration and Financial Services, AAKaren Jensen, Manager, Research Administration, SPACarol Mitchell, Controller, USNHFrancine Ndayisaba, Accounting Manager, USNHLisa Pollard, Purchasing Manager, USNHKate Roberts, Director of Financial Services, CEPSKerry Scala, Finance Director, VPFA OfficeDenise Smith, Director of Purchasing, USNHVictor Sosa, Director, Sponsored Programs AdministrationScott Towle, Manager Cost Analysis, VPFA Office
3 What is Uniform Guidance 2 CFR 200A-87A-89A-110A-21A-133A-102A-50A-122Uniform Guidance (UG) is a combined, simplified, version of 8 circulars.
4 Institutions of Higher Ed (IHE) Replaces Existing Circulars:All included in 2 CFR 200Applies to:StatesNon-ProfitsTribal NationsEffective Date:Guidance for Federal and Non-Federal Entities that applies to:GrantsCo-op AgreementsContracts**Federal contracts follow the FAR, plus UG for cost principles.Institutions of Higher Ed (IHE)December201426
5 Uniform Guidance Themes Making the most efficient use of federal fundsMore flexibility in the direct cost category, as long as purchases meet the same direct cost standard (allowable, allocable and reasonable) and follow Internal ControlsInternal Controls references throughout the document; require clear roles and responsibilities; and monitoring to ensure complianceCloseouts:Not new BUT more pressure from agencies for 90 day close outs.Subawards will need to close in 45 – 60 daysOnly NSF has issued implementation guidelines, other agencies yet to weigh in
6 The Good, The Bad and the ???What the guidance is and what (we think) it meansMuch depends on the agency implementations, which with the exception of NSF, remain unknown.
7 Pre-Award – Good!!! Standard Information Funding Opportunities need to include standard info – not a change but good to knowPrescribed ElementsPrescribed format, review criteria, cost share requirements, due dates, deviations in standard terms and conditions, additional reports60 Days Lead TimeGenerally, 60 days lead time for funding announcements, unless shorter notice is specifically approved by agency head – minimum of 30 days lead time.
8 Pre-Award – Good! Pre-Approved Terms & Conditions Agencies must use pre-approved terms and conditions, or describe deviations at proposal stageApproval of ExceptionsAny exception to terms and conditions (e.g., limits on F&A) must be approved by the agency head and posted on the OMB websiteTracking of ExceptionsOMB will be tracking exceptions to policies, evaluating the effectiveness of the UG through metrics
9 Subrecipient Monitoring – Do you want to hear the good news first? Increased burden for vendor vs. subrecipient classificationF&A ImprovementF&A rate agreement must be honored if one existsSubrecipient (e.g., foreign, small businesses, etc.) without a negotiated rate can get an automatic 10% MTDC F&A rate.Prime recipient makes the determination between Subrecipient vs. Professional Services/Vendor and we need to document how we make the decision each timeFixed Price Sub AwardsAgency must grant prior approval for issuing fixed price subawardsNew maximum limit for fixed price subawards $150KPotentially more risk assessment burden for OSP as audit threshold increases to $750K, time will tell
10 Subrecipient Monitoring ‐ +/‐ Fully documented risk assessment for each sub prior to issuance.New obligation to be able to prove that UNH (the PI!) received and reviewed the subrecipient’s performance and financial reports
11 Cost Share – All Good!Voluntary committed cost sharing is NOT expected, could be basis for exclusion (NSF)Cost sharing requirements must be included in the funding announcementCost sharing may not be used as a factor in reviewing proposals or as merit criteria
12 Changes in F&A Cost Rulings - Good Federal agencies are expected to honor negotiated F&A RatesClass or single award exceptions only when required by Federal statue or regulation, or approved by an agency head or delegateExceptions must be reported to OMBPolicies, procedures and general decision making criteria for making exceptions must be publishedParticipant Support CostsMust be excluded from F&A (similar to NSF Model)
13 Award Notices – Good!All federal awards must include clear terms and conditions (for the entire award period), including:Reporting requirementsFormatDue DateAny deviations from agency policyProvide a basis for objecting when agency layers on additional requirements (e.g., prior approvals, reporting) during the life of an award
14 Award Terms – More Good! WORKING OFF-SITE Recognition that technology allows a PI to be away from campus and still be engaged in the project“Disengagement” from the project for more than three months, rather than “absence” from the project.
15 Document Retention - Good! – Electronic Record states that there is no need to create a paper record for a record that was originally electronic and cannot be alteredMay convert paper to electronic, provided the records are:Subject to periodic quality control reviewsProvide reasonable safeguards against alteration, andRemain ReadableStill a conflict between UG and FAR which states that paper records must be kept for a year after paper records are converted to an electronic form..pdf
16 Direct Costs – Good! Computing Devices Considered supply costs (if it’s under $5K); can be charged as a direct cost when devices are “essential and allocable to a project”, but not “solely dedicated” to the performance of the award; need standards for documentationPublication Costs (Page Charges)Page charges are still allowable costs after award end date but before closeout (in essence, adoption of the NSF model); costs must be consistently charged as a direct cost.Admin and Clerical SalariesEliminated “major project” referenceMay be direct charged when services provided are:Integral to the awardSpecifically identified with the activityIncluded in the budget or have prior written approval of the Federal Agency
17 Other Cost Items Travel Costs Conference Costs Temporary dependent care costs above and beyond regular dependent care that directly results from travel to conferences, is allowable provided:Cost is direct result of individual’s travel for the federal award,Cost is consistent with non-federal entity’s travel policy for all travel (not just sponsored), andCost is only temporary during the travel periodConference CostsRequires conference hosts to exercise discretion and judgment to ensure that conference costs are appropriate, necessary and managed in a way that minimizes cost to the federal award (remember the notion of waste and abuse)‘As needed, the costs of identifying, but not providing, locally available dependent-care resources are allowable’Recruitment CostsClarification is made that now allows short term travel visas (but not longer term immigration visas)University travel policies will be evaluated for current and future practices, as the Uniform Guidance requires consistent treatment between federally funded programs and non-federal programs.
18 Time & Effort Reporting Strengthening of Internal ControlsExamples that used to be provided have now been removed.These prior examples had been interpreted by auditors to be the prescriptionThe term ‘Effort Reports’ is no longer explicitly mentionedNote: While the prescriptive language has changed, and examples removed, there is still a strong focus on accountability and internal controls regarding compensation on federal awards. UNH will review the guidance carefully and evaluate current and future processes for effort reporting.
19 Purchasing – Some challenges All procurement between the micro-purchase level ($3K) and the Simplified Acquisition Threshold ($150K) must be competitive – how will we implement?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.Also stresses Small and Minority Owned Business Issues
20 Internal Controls – More Scrutiny Requires us to have strong, internal controls.Council on Financial Assistance Reform (COFAR) offers the following source documents to be used as best practice, but are not prescriptively required“Standards for Internal Control in the Federal Government” (Green Book) issued by the Comptroller General.“Internal Control Framework” issued by the Committee on Sponsoring Organizations (COSO)Could lead to:Stronger audit scrutiny and emphasis on documentation!Expect efforts to limit cost transfers and late salary transfers.
21 Spending at the End of Award – More Scrutiny No more than $5K in materials remaining at the end of the grantImplies closer scrutiny on overall spending in the last few months of the award – may need closer financial monitoring
22 Performance Reporting Continued pressure from agencies to relate research progress to financial information and other “data” (e.g., number of students, publications, patents)Guidance provides for research sponsors to use standard Research Performance Progress Report (RPPR) format – depends on agency implementation (NSF is on board!)
23 Financial Reporting – Didn’t see this coming New certification for financial reports – statutory penalties for false certificationsI certify to the best of my knowledge and belief that the report is true, complete, and accurate and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise.
24 Closeouts – More Pressure on 90 Days No change in federal requirements, but agencies are becoming more stringentAll reports are due “no later than 90 calendar days after the end date of the period of performance”Why?Pressure on agencies – memo from OMB July 2012New sub-accounting – NSF, NIH, others to comeNo cash draws on awards after 90 days, except in exceptional cases, as approved by the agencyApplies to all reports – PIs get readyFocus on more timely financial review
25 Top Issues To Be Aware Of Many good things in the UGStill waiting for agencies to weigh inDocumenting and monitoring internal controls – where we have gapsPrice competition is keyCloseouts – in 90 days, for real!
26 Next StepsWorking group is continuing to determine full implications and impact of UGWeb page has been developed and updates will be postedTraining for the UNH communityTiming is an issue – dependent on agency implementationsCommunicatingIdeas?