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. 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 Beyond consolidation of the eight documents into one, the other stated goals were to update the outdated requirements in the former circulars and to reduce some of the administrative burdens created by the former circulars.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. UTK collaborated with both COGR and FDP by providing our questions and concerns regarding the UG. On 8/29/14, COFAR issued an FAQ which addressed some of these concerns and questions. Further discussions continue regarding outstanding issues and concerns.
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 may change (e.g., computers and support staff).
- More subrecipient information. Subrecipients will be subject to a risk assessment, so more information will likely be required from potential subrecipients at the time of proposal submission and award. More reporting may also be required of subrecipients.
- 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.
We are awaiting clarification on some of the sections of the Uniform Guidance and will update this page as more information becomes available.
What is UT doing 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 are not enormous, but they will have significant impact in some areas. Some regulations offer some flexibility and other areas will require some additional items to be addressed at the proposal stage to ensure we can fully benefit from the changes. The Working Group members are creating resource documents that will be shared as soon as they are finalized.
What is UT doing to get the word out?
Several of the Office of Research & Engagement (ORE) personnel are part of the UG Working Group addressing the required changes. On a monthly basis ORE has provided the Associate Dean’s for Research an update on the work the UG Working Group has done. The Office of Sponsored Programs (OSP) held an information session during the October, 2014 Research Administrators OutReach Forum (RAOR) and the OSP Director was a guest speaker at the Professional Development Administrators Committee (PDAC) group addressing the upcoming changes in response to the UG.
The Office of Research & Engagement will be holding Town Hall sessions to discuss the Uniform Guidance. A panel of experts will provide a brief presentation addressing the changes and will open the floor for open discussion. These sessions will be held in early 2015. Check the ORE Training pages for specific dates and locations of the Town Hall sessions.
When will the Uniform Guidance apply?
The Uniform Guidance administrative requirements and cost principles will apply to new and incremental funding awarded after December 26, 2014. Existing Federal awards 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 Sponsored Programs.
Jean Mercer, Director
Theresa Sears, Assistant Director, Contracts
David Smelser, Assistant Director, Proposals
Uniform Guidance Agency Presentations
Uniform Guidance Tools
- Subrecipient Monitoring Plans
- Subaward Responsibilities Matrix
- Determination Guide for Agreements with External Enttities/Individuals
- Subrecipient Risk Assessment for New Subrecipients
Direct vs Indirect Charging Tools
- PI Quick Guide to Exceptions
- Direct vs F&A Charges Guide
- Unallowable Costs Guide
- UT Justification Samples Example Guide