Uniform Guidance: What You Need to Know

Dear Colleagues: Amherst College must be prepared for the implementation of new federal grant guidelines called the "Uniform Guidance" (UG). In order to support faculty and staff in understanding these changes, the College has put together this webpage to highlight the information that you need to know. The UG, which is written by the Office of Management and Budget (OMB), will go into effect on Dec. 26, 2014. Here is how the new guidance will affect faculty and departmental research administrators. 

1)  The new UG applies to new awards only. Existing awards will continue under the existing rules.What this means: For a while, you may have grants under two different sets of regulations.

2)  Under the UG, federal agencies must accept a university’s negotiated indirect cost rate. There can be exceptions with federal agency head approval.

3)  Federal agencies must post funding opportunities at least 60 days prior to a deadline.

4)  Voluntary committed cost share is no longer expected. Agencies can’t state in a Request for Application (RFA) that “cost share isn’t required but is preferred.” They must either require it (i.e., mandatory cost share) or not consider it at all. (CFR 200.306 Cost sharing or matching)What this means: Do not add cost share in your proposal unless it is required by the agency.

5) The UG requires procurement methods with dollar thresholds. (CFR 200.320 Methods of procurement) Purchases under $3,000 are considered “micro-purchases” and do not require competitive quotes. Purchases between $3,000 and $150,000 require quotes from an “adequate” number of qualified sources. Purchases over $150,000 require sealed bids or competitive proposals. (Email us for more info.) The one exception: If you can only obtain materials from a single source, then these rules do not apply. You would in this case need to document the fact of “sole source procurement.”What this means: Purchases over $3,000 now require at least two competitive quotes from vendors. The only exception is when you have a documented need for sole source procurement. There is a three year grace period for implementing this requirement.

6) Clerical and administrative salaries can be directly charged if they are integral to a project or activity and are also directly allocable. Such costs must be explicitly explained in the budget and/or have prior approval from the sponsor. (CFR 200.413 Direct costs)More info.

7)  Under personnel compensation, there is now a clarification of the institutional base salary concept at universities. Institutions must establish consistent written policies that apply uniformly to all faculty members, not just those working on federal grants. The requirements for effort reporting have changed, with an emphasis on strong internal controls. (CFR 200-430 Compensation-personal services)More info.

8)  Computers and computing devices can be directly charged to grants if they are essential and allocable. Most computing devices fall well below the federal Equipment threshold ($5,000), and thus are counted in the budget as Supplies. There is no longer a requirement that they be solely used for the project at hand; however, they should be used mostly for the project. (CFR 200.453 Materials and supplies costs)What this means: You can now include computers and computing devices in your Supply budget, but must provide written justification for their purchase.

9) Institutions must submit performance reports using OMB-approved government-wide standard information collections. Required information includes a comparison of actual accomplishments to those that were proposed for the reporting period, the reasons why goals were not met (if applicable), and an analysis and explanation of cost overruns. (CFR 200.328 Monitoring and reporting program performance)(Call or email us with specific concerns.)

10) Before issuing an award, the Federal awarding agency will evaluate the risk posed by the institution. The risk assessment will review the institution’s financial stability, the reports and findings from its audits, and its history of performance around compliance and report requirements. (CFR 200.205 Review of risk posed by applicants)What this means: An individual faculty member who routinely misses reporting deadlines will adversely affect other faculty members' ability to win future grants.

(Parts of this summary were adapted from VCU’s Sponsored Program’s office website.)

Entire Uniform Guidance here.    

UG FAQs here.

 

Questions? Please contact Kiku Ichihara at x2804 or at