Spotlight on Uniform Guidance
June 2014
In December 2013, the Federal Office of Management and Budget (OMB) issued its final Uniform Guidance (UG) on administrative requirements, cost principles and audit requirements for federal awards, which include research grant awards to Institutions of Higher Education (IHE). The UG unifies eight different circulars that have guided federal assistance management for many years (e.g. Circular A-21 for cost principles with educational institutions was last revised in 2004; Circular A-110 for administrative standards for federal grants was last revised in 1993 and amended in 1999). The goal of OMB's UG is to accomplish the President's directives to (1) streamline guidance for federal awards in order to ease administrative burden, and (2) strengthen oversight of federal funds to reduce risks of waste, fraud, and abuse. The UG complements ongoing efforts by OMB and other federal agencies to modify grant-making approaches.
The UG is expected to impact - directly and/or indirectly – many IHE areas that are associated with federally sponsored research, such as purchasing, effort and financial conflict reporting, institutional certifications, application reviews, internal controls and audits, training needs, and sub-recipient monitoring. Each grant-making agency is now developing its own UG implementation plan and some differences between agencies are anticipated.
The UG will apply to new awards and increments to existing awards made on or after December 26, 2014, unless OMB grants an extension. Given this challenging time-frame and scope, the IHE community is awaiting OMB and agency clarifications on whether federally-funded grantees would initially have to manage awards under two sets of requirements (old and new) and on other implementation details.
We will continue to keep the RU community informed on new policies and regulations that may impact sponsored research operation and management.
Critical Dates
December 26, 2013: UG released
June 2014: Agencies' UG implementation plans due
December 26, 2014: UG in effect
Sources
‘University Perspectives’ on Uniform Guidance Report by COGR, FDP and Federal Partners, June 6, 2014
Uniform Guidance on SR-PD Site
