UF Implements New OMB Uniform Guidance

The White House Office of Management and Budget (OMB) has issued Uniform Guidance 2 CFR 200 revising administrative requirements, cost principles, and audit requirements for federal awards. The modified regulations place increased emphasis on institutions to strengthen their internal control processes over the management of funds in order to provide reasonable assurance of effective and efficient operations, reliability of reporting, and compliance with laws and regulations.

The major points of emphasis and implications for UF at this time are as follows:

All costs must be reasonable, allocable, and necessary to the performance of the work.

• Computing Devices – The Uniform Guidance allows the direct charging of computing devices, costing less than $5,000 as a material and supply cost provided they are essential and allocable to the project. Computing devices do not have to be solely dedicated to the performance of a federal award, in order to be charged 100% to a single award or allocated to several awards. Computer devices are expected to be primarily used to support the performance of the federal award. The UF Division of Sponsored Programs (DSP) will continue to require CAS exemption forms for these items.
  DSP recommends that for any project where a computer is essential and allocable and can be documented as such, to include these items in your budget and justification starting immediately.

• Administrative and Clerical Support – The Uniform Guidance clearly states salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs; however, direct charging of administration and clerical costs may be appropriate to a federal award only if all of the following conditions are met:
  • Administrative or clerical services are integral to a project or activity.
  • Individuals involved can be specifically identified with the project or activity.
  • Such costs are explicitly included in the budget or have the prior written approval of the federal awarding agency.
  • The costs are not also recovered as indirect costs.
  DSP recommends starting immediately for the budget justification to include the positions, cost, reason the project has a need for dedicated administrative and clerical personnel, and the role these individuals will play. If awarded, DSP will require a CAS exemption form to be approved for these charges to be expensed to your project. DSP recommends that administrative or clerical time must exceed 20% of an individual’s total effort to be proposed as direct charged to any sponsored project. Any effort less than 20% should generally be recovered as indirect costs.

• Effort Reporting – The standards for documenting personnel charges on sponsored projects remain. There is some flexibility in the method of documentation, but the overall policy and requirements are not changed. UF will work to clarify its policy on Institutional Base Salary but anticipates no procedural changes. Effort reporting in myUFL will continue once per semester for all individuals paid or cost shared on sponsored projects.

• Subrecipient Monitoring – There is an increased emphasis on the role of the prime award recipient in monitoring the fiscal and programmatic performance of its subrecipients. UF is required to evaluate each subrecipient’s risk of noncompliance with federal regulations and the terms of the award for the purposes of determining the appropriate subrecipient monitoring. PIs on projects with subrecipients will be required to collect, review, and retain subrecipient’s programmatic reports as required by the terms of the subaward and continue to review invoices and ensure that the subrecipient is performing work at least equivalent to the charges billed.

• Fixed Price Outgoing Subawards – Sponsor prior approval will be required in order for UF to issue a fixed price subaward rather than a cost-reimbursement subaward. The total cost of each fixed price subaward may not exceed $150,000. UF typically uses fixed price subawards with foreign subrecipients, clinical trial site agreements, and occasionally with small organizations. UF will consider the fixed price subaward approved if the award is made and no contrary guidance has been provided by the sponsor in the award notice.
  Starting immediately, DSP recommends that for any project where an outgoing subaward is contemplated to be fixed price, a clear statement must be included in the proposal/budget justification that indicates the budgeted subaward for (insert subrecipient name) will be issued as a fixed price subaward.

• Fixed Amount Awards – UF will require that all budgets for all types of awards are built, routed, and approved at a minimum category level budget, with key personnel broken out by name and effort commitment. The guidance requires that any deviation from the effort commitment, even for fixed amount awards, by 25% or more be approved by the sponsor, in writing, prior to the change.

• Closeout – There is increased scrutiny on the timeline for closeout of an award. UF has already experienced increased pressure from sponsors to ensure timely closeout of all awards. PIs and administrators are encouraged to monitor charges throughout the life of the award to expedite the fiscal closeout. In addition, PIs are expected to file all technical and invention reports within 90 days of the expiration of the award.

• Participant Support Costs – Participant support costs in all budgets will be excluded from the F&A base. UF is seeking clarification whether this applies immediately to all budgets or only after the next F&A agreement is negotiated.

• Procurement Requirements – There are significant changes in the procurement requirements. They are so significant that the research community was successful in delaying the implementation for one year (until 7/1/2016). These changes will require bids, quotes, and increased documentation on all purchases greater than $3,000.

Please see the UF Office of Research Uniform Guidance Implementation webpage for more information.