What is the Uniform Guidance?
In December 2013, the Office of Management and Budget (OMB) issued the “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, or “Uniform Guidance”; Uniform Guidance (UG) replaced and consolidated the following Circulars (OMB Circulars A-21, A-50, A-87, A-110, A-122, A-89, A-102, and A-133), with the aim to streamline guidance and provide a Government-wide framework for grants management.
The Research Operations Office organised a training event on the audit requirements of US federal grants, led by ROO and LEES Chartered Certified Accountants. The recording and the presentation slides can be accessed via the Grants Administration (sharepoint.com).
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.
Timesheet templates and declaration form can be accessed via ROO's sharepoint.
Historical template
The old template for time recording for US federal grants can be downloaded from here. This form can still be used but we recommend to use the new generic template for all funders available from ROO's sharepoint.
Overhead recovery
The university does not have a negotiated rate with any US federal agency, hence for NIH grants we receive a rate of %8 for overhead. For other federal agencies, on most of cases, a rate of %10 is acceptable.
However, depending on the sponsored we might be able to negotiate FEC rate at the time of application.
Please note in such cases, the claimed overhead need to be propionate to the staff effort and hence backed up by evidence of staff working on the project (directly and indirectly), to support the claimed overheads.
For indirect staff the evidence can be an annual declaration, signed by line manager, confirming the % of time spent on the Federal 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.
In summary in addition to flowing down the grant’s T&Cs:
- A comprehensive due diligence check is required in advance of starting the collaboration; plesae contact your relevant Research Support Advisor to arrange this.
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Scientific progress needs to be monitored by PI periodically and evidence documented.
- Sub-recipients need to be monitored on annual basis to ensure compliance with requirements of Uniform Guidance. Sub-recipient monitoring form can be downloaded from here.
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.
RGUG presentation on Uniform Guidance
In addition, our auditors Lees have produced guidance notes for grant holders following their attendance at the National Council of University Research Administrators in Washington DC.
US Dept of Education Implementation of the Uniform Guidance
NSF Implementation of the Uniform Guidance
The Proposal & Award Policies & Procedures Guide (PAPPG), together with National Science Foundation (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.
The external audits of the Review of US federal Grants (NIH only for 2013 and 2014) for A-133 Compliance can be found here
The University is required to conduct an annual audit in accordance with the guidelines set out in 2 CFR Part 200 Uniform Guidance on all of its Department of Health and Human Services (e.g. NIH, CDC, etc) and USAID (International Development) grants, as part of the terms and conditions of these grants.
The audit is conducted on a sample basis and around 20% of our Federally funded grants are sampled annually for review. This will be a single audit in accordance with Subpart F of the Uniform Guidance.
LEES Chartered Certified Accountants is appointed by the University as the auditor for our Federal grants.
A document delineating the generic documentations required for Single Audit can be downloaded from here.
In addition, our auditors Lees have produced guidance notes for grant holders following their attendance at the National Council of University Research Administrators in Washington DC.