The Office of Management and Budget (OMB) previously had 8 Circulars related to grants management and proper spending of Federal funds. To streamline administrative efforts, Uniform Guidance (UG) replaces and consolidates those Circulars (OMB Circulars A-21, A-50, A-87, A-110, A-122, A-89, A-102, and A-133). In consolidating the Circulars, OMB also updated outdated requirements to ease administrative burdens. OMB created the Council on Financial Assistance Reform (COFAR), an interagency group, and delegated the responsibility to COFAR to lead the development of Uniform Guidance. The final UG rule was issued on December 26, 2013 with an implementation date of December 26, 2014.
UT continues to be involved with the Council on Governmental Relations (COGR) and the Federal Demonstration Partnership (FDP) in a collaborative effort to ensure universities’ concerns and needs are being addressed. Internally, the UT Controller formed a Uniform Guidance Working Group to revise UT fiscal policies to reflect changes. While making these updates, representatives from all campuses had the opportunity to talk through policies and actual practices across the university and improve fiscal policies in areas unrelated to the UG changes.
Many of the changes are administrative and may not change the way you conduct business daily. Here are some changes that could affect you and your federal awards or sub-awards:
- More time to prepare applications. The UG requires that federal agencies post funding opportunities at least 60 days before a deadline.
- More F&A recovery. Federal agencies must accept an institution’s negotiated F&A rate unless the head of the agency approves otherwise.
- Administrative expenses as direct costs must be approved by agency. If a proposal includes as a direct cost any item that appear to be administrative (F & A type expense, such as a computer or administrative salary), the budget justification should include a clear and detailed justification for including the cost.
- Procurement of Small Purchases, starting at $3,000, is a problem point. UG requires obtaining quotes for purchases $3,000 to $149,999. UT and most other organizations have a higher limit than $3,000, so this adds an administrative burden. COGR is fighting this requirement. Fortunately, implementation of this requirement has been delayed.
- More sub-recipient information. Sub-recipients will be subject to a risk assessment, so more information will likely be required from potential sub-recipients at the time of proposal submission and award. More reporting may also be required of sub-recipients.
The Uniform Guidance administrative requirements and cost principles apply to new and incremental funding awarded 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 amended by the federal sponsor.
For any questions about UG, you may contact the the Office of Sponsored Programs at 865-974-7537.
Direct vs Indirect Charging Tools
Uniform Guidance (2 CFR 200)-Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
Uniform Guidance FAQ
Council on Financial Assistance Reform (COFAR)
COGR Guide to Uniform Guidance