UNIFORM GUIDANCE OVERVIEW Budget Officers Meeting January 28, 2015
OMB Circulars Before and After Eight circulars condensed to one new comprehensive set of requirements for recipients of federal awards 2 CFR Chapter 1, Chapter 2, Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
Important Dates Applicable to new awards and new funding increments issued on and after December 26, 2014 UG is actually guidance to agencies and each agency had to submit a draft implementation to OMB by June 26, 2014 Final Agency implementation plans released December 19, 2014
University of Kentucky Plan Steering Committee Eric Monday, Executive VP for Finance for Finance and Administration Lisa Cassis, Interim Vice President for Research G.T. Lineberry, Associate Provost for Faculty Advancement & Institutional Effectiveness Working Group Co-Chaired by Jennifer Miles, Director Sponsored Projects Accounting and Deborah Davis, Associate VP for Research, Director Office of Sponsored Projects Administration Includes faculty, associate deans for research, center director, college level business officer, directors of administrative units affected by UG (HR, Purchasing, Risk Management, General Accounting, Legal Counsel, Graduate School, Accounts Payable..) And co-chairs are consulting with Subject Matter Experts not on the Working Group
Investigator Quick Guide Administrative and Clerical Salaries 200.413 Still, normally indirect and should not be direct charged However, may be appropriate if ALL of these criteria are met: Services are integral to a project or activity Individuals involved can be specifically identified with the project (normally not less than 15% commitment) Costs are explicitly included in proposal budget or have sponsor prior written approval Not also recovered as indirect Prior written approval of the awarding agency must be obtained. If all of these requirements are met, Investigators/departments should add a new justification statement to proposals to facilitate the required agency approval. The budget justification must include a narrative that explains how these services are integral to the project.
Investigator Quick Guide Programmatic Salary Costs 200.430 Costs related to protocol development and maintenance, managing substances/chemicals, managing and securing project-specific data, and coordination of research subjects are allowable direct costs when they are contributing and directly related to work under an agreement. Thus, these programmatic costs may be direct charged using the same underlying requirements as other types of direct costs, and are not subject to the extra approval requirements applicable to administrative and clerical costs. They are still subject to all regular costing requirements (e.g.; allocability, reasonableness, allowable by the terms of the award, incurred within award period).
Investigator Quick Guide Computing Devices 200.33, 200.48, 200.89, 200.439, 200.453C For awards effective 7/1/2015 and later Computing devices under $2000 per unit may be direct charged if: The device is essential* and allocable to the project in that it is necessary to acquire, store, analyze, process, and publish data and other information electronically, including accessories (or peripherals ) for printing, transmitting and receiving or storing electronic information. The project does not have reasonable access to the other devices or equipment that can achieve the same purpose; devices may not be purchased for reasons of convenience or preference. Items costing $2,000 or more per unit are considered general purpose equipment and follow federal equipment rules for when they can be direct charged. NOTE: $2000 is an anticipated dollar threshold; this issue is under review by the university. *Investigators are responsible for determining whether or not the device is essential and to what extent the cost of the device is allocable to the sponsored project. Investigators and departments should maintain documentation that describes how the proposed computing device meets the above requirements. The computing devices should be listed in the budget under materials and supplies and are subject to Facilities and Administrative costs (F&A).
Investigator Quick Guide Participant Support Costs 200.75, 200.456 Participant support costs are allowable with agency prior approval. This includes stipends or subsistence allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects. Participant support costs are not routinely allowed on research projects but can be charged if the project includes an education or outreach component and the agency approves such costs. These costs should be explicitly listed in the proposal budget or approved by the funding agency after the award has been made. These costs must be excluded when calculating the Modified Total Direct Costs (MTDC) to determine the project s F&A costs, therefore, a separate scope account will be established when these costs are included in the awarded budget.
Investigator Quick Guide F&A on Subawards 200.331 A subrecipient s negotiated F&A rate or an alternative rate as described as follows must be used for all subawards included in competitive proposals. If a federal program has a published statutory F&A cap, that rate must be used both by UK and all of its subrecipients. For all other federal programs, if a subrecipient has a federally negotiated F&A rate, it must be used. If the entity does not have a negotiated F&A rate, a 10% MTDC de minimis F&A rate must be used instead. Investigators may not negotiate or agree to lower rates with their subrecipients.
Investigator Quick Guide Fixed Amount Subawards 200.201, 200.332 Agency prior approval is required to enter into a fixed amount subaward rather than a cost-reimbursement subaward, and the total value of each fixed amount subaward may not exceed $150K. To expedite agency approval, Investigators/departments should add a new justification statement to a proposal contemplating a fixed amount subaward which addresses why it is appropriate to use this funding mechanism (see 200.201). A statement is not needed for cost reimbursement subawards.
Investigator Quick Guide Voluntary Committed Cost Sharing 200.306 Under the UG, funding agencies are prohibited from considering voluntary committed cost sharing in the merit review process. The National Science Foundation specifically prohibits voluntary committed cost sharing in proposals, unless specified in the funding opportunity announcement. Since the federal agencies cannot consider voluntary committed cost sharing in assessing a proposal s merit, offering it will not increase the likelihood of an award. Cost sharing means project costs not borne by the sponsor; also known as matching or in-kind contributions. Voluntary committed cost sharing is cost sharing that is not required by law, statute or regulation, nor written in the application guidelines, but was offered by the investigator in the proposal. Voluntary committed cost sharing is recorded in the University s accounting system and must be reported internally. (See also BPM E-50-2)
Procurement 200.317 326 Procurement Standards Grace period until 7/1/2016 but much work to be done Micro-purchases: $3000 or less, no competition required Small purchases: $3000 - $149,999, price or rate quotations required from adequate number of sources Simplified Acquisition Threshold is $150,000 Sealed bids RFPs
Procurement Using Contract vendors will prevent need for additional documentation of competition under UG http://www.uky.edu/purchasing/pcts.htm Anticipate separate processes for federal UG procurement and other sources Ability to visually identify federal UG funds by specified number ranges in the future Quotes from vendors used in proposals may exclude the vendor from procurement process if awarded.
Actions taken within UK: Documentation of personnel expenses Huron currently completing an Effort Review with report due in February Official definition of Institutional Base Salary Legal Counsel has draft Administrative Regulation prepared Commercial air travel 200.474(d) UG would allow lowest unrestricted airfare which is much more expensive than lowest restricted (non-refundable) UK will not change existing travel policy Programming needs submitted to EAG and projects are approved
Going forward Much we do not know Actively reviewing the Agency implementation plans Actively tracking new UG awards New awards will note in the PADR Remarks that the account is subject to UG
Resources/Information Uniform Guidance Federal Register Announcement http://www.gpo.gov/fdsys/pkg/fr-2013-12-26/pdf/2013-30465.pdf Chief Financial Officers Council (COFAR) Includes FAQs https://cfo.gov/cofar/ UK Uniform Guidance webpage http://www.research.uky.edu/ug/ Investigator Quick Guide http://www.research.uky.edu/ug/investigator%20quick%20 Guide.pdf
Resources/Information E-mail to Working Group - Uniform.Guidance@uky.edu Jennifer Miles Director of Sponsored Projects Accounting (SPA) jennifer.miles@uky.edu Debbie Davis Director of Sponsored Projects Administration (OSPA) deborah.davis@uky.edu