1. University of New Hampshire
Uniform Guidance (UG!)
University of New Hampshire

2. Uniform Guidance Team
Jan Nisbet, Project Sponsor, Senior Vice Provost for Research
David Browning, Project Manager, Financial Research Administration, SPA
Jo Beth Dudley, Director of Finance and Administration, EOS
Vicki Escalera, Director of Internal Audit, USNH
Louise Griffin, Director of Administration, SVPR
Nancy Hamer, Director of Administration and Financial Services, AA
Karen Jensen, Manager, Research Administration, SPA
Carol Mitchell, Controller, USNH
Francine Ndayisaba, Accounting Manager, USNH
Lisa Pollard, Purchasing Manager, USNH
Kate Roberts, Director of Financial Services, CEPS
Kerry Scala, Finance Director, VPFA Office
Denise Smith, Director of Purchasing, USNH
Victor Sosa, Director, Sponsored Programs Administration
Scott Towle, Manager Cost Analysis, VPFA Office

3. What is Uniform Guidance
2 CFR 200
A-87
A-89
A-110
A-21
A-133
A-102
A-50
A-122
Uniform Guidance (UG) is a combined, simplified, version of 8 circulars.

4. Institutions of Higher Ed (IHE)
Replaces Existing Circulars:
All included in 2 CFR 200
Applies to:
States
Non-Profits
Tribal Nations
Effective Date:
Guidance for Federal and Non-Federal Entities that applies to:
Grants
Co-op Agreements
Contracts*
*Federal contracts follow the FAR, plus UG for cost principles.
Institutions of Higher Ed (IHE)
December
2014 26

5. Uniform Guidance Themes
Making the most efficient use of federal funds
More flexibility in the direct cost category, as long as purchases meet the same direct cost standard (allowable, allocable and reasonable) and follow Internal Controls
Internal Controls references throughout the document; require clear roles and responsibilities; and monitoring to ensure compliance
Closeouts:
Not new BUT more pressure from agencies for 90 day close outs.
Subawards will need to close in 45 – 60 days
Only 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 means
Much 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 know
Prescribed Elements
Prescribed format, review criteria, cost share requirements, due dates, deviations in standard terms and conditions, additional reports
60 Days Lead Time
Generally, 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 stage
Approval of Exceptions
Any exception to terms and conditions (e.g., limits on F&A) must be approved by the agency head and posted on the OMB website
Tracking of Exceptions
OMB 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 classification
F&A Improvement
F&A rate agreement must be honored if one exists
Subrecipient (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 time
Fixed Price Sub Awards
Agency must grant prior approval for issuing fixed price subawards
New maximum limit for fixed price subawards $150K
Potentially 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 announcement
Cost 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 Rates
Class or single award exceptions only when required by Federal statue or regulation, or approved by an agency head or delegate
Exceptions must be reported to OMB
Policies, procedures and general decision making criteria for making exceptions must be published
Participant Support Costs
Must 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 requirements
Format
Due Date
Any deviations from agency policy
Provide 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 altered
May convert paper to electronic, provided the records are:
Subject to periodic quality control reviews
Provide reasonable safeguards against alteration, and
Remain Readable
Still 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 documentation
Publication 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 Salaries
Eliminated “major project” reference
May be direct charged when services provided are:
Integral to the award
Specifically identified with the activity
Included 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), and
Cost is only temporary during the travel period
Conference Costs
Requires 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 Costs
Clarification 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 Controls
Examples that used to be provided have now been removed.
These prior examples had been interpreted by auditors to be the prescription
The term ‘Effort Reports’ is no longer explicitly mentioned
Note: 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 grant
Implies 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 certifications
I 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 stringent
All 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 2012
New sub-accounting – NSF, NIH, others to come
No cash draws on awards after 90 days, except in exceptional cases, as approved by the agency
Applies to all reports – PIs get ready
Focus on more timely financial review

25. Top Issues To Be Aware Of
Many good things in the UG
Still waiting for agencies to weigh in
Documenting and monitoring internal controls – where we have gaps
Price competition is key
Closeouts – in 90 days, for real!

26. Next Steps
Working group is continuing to determine full implications and impact of UG
Web page has been developed and updates will be posted
Training for the UNH community
Timing is an issue – dependent on agency implementations
Communicating
Ideas?