In December 2013, the Office of Management and Budget (OMB) issued “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards”; Uniform Guidance (UG) replaces and consolidates existing Circulars (OMB Circulars A-21, A-50, A-87, A-110, A-122, A-89, A-102, and A-133), and aims to streamline guidance and provide a Government-wide framework for grants management.
Changes were implemented on December 26, 2014, with the exception of the audit requirements, which are effective the first fiscal year after December 26, 2014. Federal awards that were in existence at that date continue to be governed by the terms and conditions under which they were awarded, unless officially modified by the Federal sponsor to incorporate all or part of the Uniform Guidance.
When additional funding (Supplement, Increment or Renewal) is received, the modification could require the entire Award (both the new funds and any carryover funds) to be subject to the Uniform Guidance or only the new funding to be subject to the Uniform Guidance.
There are some points in the guideline as summarised below which have clear implications on the way US Federal funded awards are managed:
· Effort reporting
One of the key areas of change resulted from the Uniform Guidance is the requirements related to tracking and reporting of staff costs. The requirements are outlined in 2 CFR 200.430. Briefly, the minimum that can be accepted as evidence is:
- An assessment of time completed by the researcher, covering all of their time on a monthly basis (either hourly, i.e., a timesheet), showing 100% of their time in total.
- This time assessment must be authorised by their direct supervisor, or someone who knows where they have spent all their time.
The requirements also apply to staff working 100% on a federal funded grant.
· Value Added TAX (VAT)
Previously, VAT was an unallowable cost (NIH grant policy statement dated 10/1/2013; part 16.6). VAT is now an eligable cost on Federally funded grants (2 CFR 200.470):
“Value Added Tax (VAT) Foreign taxes charged for the purchase of goods or services that a non-Federal entity is legally required to pay in country is an allowable expense under Federal awards.”
· Sub-recipient monitoring
Applicable parts of the Uniform Guidance should flow down from the Prime recipient to sub-recipients. In addition, the prime recipient must monitor compliance. Sub-recipient monitoring is performed by the Department at different stages of the sub agreement from proposal to award closeout. The requirements for Sub-recipient Monitoring and Management are described in section §200.331.
· Audit threshold
The triggering threshold of Federal expenditure by recipient during the fiscal period for a Single Audit requirement will be raised from $500,000 to $750,000 (2CFR 200.501).
· Audit Fee
Audit fees are now an eligible cost on Federal funded grants (2CFR 200.425):
“ A reasonably proportionate share of the costs of audits required by, and performed in accordance with, the Single Audit Act Amendments of 1996 (31 U.S.C. 7501-7507), as implemented by requirements of this part, are allowable”
Also under certain conditions as describe in the guideline:
“Pass-through entities may charge Federal awards for the cost of agreed-upon-procedures engagements to monitor sub-recipients (in accordance with Subpart D—Post Federal Award Requirements of this part, §200.330”
We recommend costing for the audit fee at the application stage.
There are many other changes that might impact conduct of research. Clarifications continue to be released and will be communicated to the departments as quickly as possible.
Sponsors, to date, with published implementation plans:
NSF Implementation of the Uniform Guidance
The PAPPG, together with NSF’s Grant General Conditions, shapes the Foundation’s implementation of 2 CFR § 200, Uniform Guidance (UG). Where the PAPPG is silent on an area covered by 2 CFR § 200, the requirements stated in 2 CFR § 200 must be followed. Answers to the most frequently asked questions about the NSF implementation of Uniform Guidance can be found in this FAQ.