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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 26 December 2014, with the exception of the audit requirements, which are effective the first fiscal year after 26 December 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. 

Annual Audit of Federal Awards

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. However the University has decided to expand the scope of the audit to all grants from all Federal Agencies, including the ones that  we are not the prime recipient . UK institutions that choose to include all Federal Agencies within their Single Audit are generally regarded as lower risk by their prime awardees, reducing the amount of evidence they are required to provide with their financial claims.

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.

Key Changes in 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.

A template for time recording for US federal grants can be downloaded from here

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.

  • 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

Sponsors with Published Implementation Plans

 

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.

NIH Implementation of the Uniform Guidance 

NEA Implementation of the Uniform Guidance

A1333 and Single Audit Reports

The external audits of the Review of US federal Grants (NIH only for 2013 and 2014)  for A-133 Compliance can be found here

NIH final report 2013 (11.65 MB)

NIH final report 2014 (1.03 MB)

Single Audit Report 2015 (17.04 MB)