What is Uniform Guidance?
The Office of Management and Budget (OMB) is the federal agency that is responsible for leading the development of government-wide policy to assure that grants are managed properly and that Federal dollars are spent in accordance with applicable rules and regulations. In the past, those regulations were captured under OMB Circulars A-21, A-50, A-87, A-110, A-122, A-89, A-102, and A-133.
In an effort towards streamlining administrative efforts, OMB has led the effort of combining eight circulars into one new document called “Uniform Guidance”. Beyond consolidation of the eight documents into one, the other stated goals were to update the outdated requirements in the former circulars and to reduce some of the administrative burdens created by the former circulars.
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.
Some of the changes in the UG are very positive, but other changes were not as clear and did not seem to properly represent the needs of research universities. In a collaborative effort between the Council on Governmental Relations (COGR) and the Federal Demonstration Partnership (FDP), regular meetings were held to discuss and clarify the concerns and questions coming from research universities. On 8/29/14, COFAR issued an FAQ which addressed some of these concerns and questions. Further discussions continue regarding outstanding issues and concerns.
As the various federal agencies implement the Uniform Guidance, their agency-specific requirements are incorporated into proposal guidelines and award terms and conditions. A group of research-centric agencies, including NSF, NIH, USDA, EPA, NASA, DOT, DOE, NIST, and Homeland Security have collaborated to develop clarifications to the Uniform Guidance as it applies to their research and research-related grants. The agencies published a draft of clarifying research terms on June 4, 2015, and public comments on the clarifications must be received by December 14, 2015. After obtaining and considering public comments, the government will prepare a final version.
Who needs to know about Uniform Guidance?
Everyone who is involved in federal research and the administration of those activities is responsible to know and understand the changes that Uniform Guidance brings.
How will the Uniform Guidance affect me?
Many of the changes are administrative and may not change the way you conduct business daily.
But there are several ways in which the changes may affect you and your federal awards or subawards; here are some of them:
- 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.
- Changes in procurement and direct charging. Some procurement and direct charging requirements have changed (e.g., computers and support staff).
- More subrecipient information. Subrecipients are subject to a risk assessment, so more information is required from potential subrecipients at the time of proposal submission and award. Subrecipients that are classified as higher risk will need to be monitored more closely.
- Effort reporting. Requirements for effort reporting to the feds have changed, but we do not expect to see major changes in UT policy or practice regarding effort reporting since UT’s current system is in compliance with the new guidance.
What has UT done to implement the new guidance?
In April 2014, the UT Controller formed a Uniform Guidance Working Group to review the UG and address all the changes, their impact and to revise any fiscal policy that needs changing to adhere to the new Guidance. The changes were not enormous, but they had significant impact in some areas. Some regulations offer some flexibility and other areas required some additional items to be addressed at the proposal stage to ensure we can fully benefit from the changes. The Working Group members created resource documents that are available under the "related links" section below.
Several UT policies were updated and new policies were created to address the Uniform Guidance. A summary of changes is available, which includes links to the revised and new policies. Policy will continue to be updated as the implementation of the Uniform Guidance proceeds and its requirements are clarified through practice.
What is UTC doing to get the word out?
ORSP staff members along with our colleagues in the Office of Research Integrity and the Office of Business & Financial Affairs were part of the system-wide UG Working Group which addressed the required changes. We were involved in several committees which updated UT Fiscal Policies to ensure that all UT campuses and institutes are in compliance with the UG. We will be sending information about the UG and the new and revised UT Fiscal Policies out to campus and hosting informational sessions to provide additional details about the Uniform Guidance and agency implementation. Stay tuned for more information!
When did the Uniform Guidance take effect?
The Uniform Guidance administrative requirements and cost principles applies to new and incremental funding awarded after December 26, 2014. Federal awards made prior to that date will continue to be governed by the terms and conditions under which they were awarded, unless officially amended by the federal sponsor.
Who can I contact if I have questions about the UG?
For any questions about the UG Working Groups or information about the changes to the regulations you may contact the Office of Research and Sponsored Programs.
Meredith Perry, Director
Angie Johnson, Assistant Director