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The New Federal Uniform Guidance:
Overview and Resources

Uniform Guidance

The Uniform Guidance is due to be implemented starting December of 2014.  The document represents the most significant changes to the regulations for grants since the 1980s.   The Uniform Guidance (aka Omni-circular or UG) was developed after a public comment period and combines eight circulars that governed various activities and entities into one combined, uniform circular.  As stated in the document the goal is  "To deliver on the promise of a 21st-Century government that is more efficient, effective and transparent, the Office of Management and Budget (OMB) is streamlining the Federal government’s guidance on Administrative Requirements, Cost Principles, and Audit Requirements for Federal awards."  

This final guidance supersedes and streamlines requirements from OMB Circulars A–21, A–87, A–110, and A–122 (which have been placed in OMB guidances); Circulars A–89, A–102, andA–133; and the guidance in Circular A–50 on Single Audit Act follow-up. Future reform efforts may eventually seek to incorporate the Cost Principlesfor Hospitals in Department of Health and Human Services regulations.

Background

The new guidance represents the work of the Council on Financial Assistance Reform (COFAR), an inter-agency group of Executive Branch officials,  established in 2011 to lead the efforts to improve the delivery, management, coordination and accountability of Federal programs and cooperative agreements.   The guidance was released in December 2013 after a public comment period and becomes effective for non-federal entities on December 26, 2014.  It is important to note that as the guidance has been reviewed by the community the government has responded with clarifications and FAQ and an extension for implementation of procurement requirements.

Highlights:

Pre-Award Requirements:   

A federal award must include General Federal Award Information, General Terms and Conditions, Federal Awarding Agency, Program or Federal Award specific T&C and Federal Award Performance Goals.

Allowable Direct Costs on Grants

Administrative and clerical staff salaries may be directly allocable if they are integral to a project or activity and theses salaries are explicitly included in the budget or have the prior written approval of Federal awarding agency.

Computing devices allowable direct cost supplies when cost is lesser of entity’s capitalization level or $5,000. Do not have to be solely dedicated to the performance of the Federal award.

Budgeting for Contingency Funds on certain awards, for construction or upgrades to large facilities or instruments and IT systems. Budgeting for and disbursing funds for costs associated with possible events or conditions arising from causes which are undeterminable at the time of budgeting are allowable.

Personnel Costs:  

More flexibility but a requirement to comply with a stringent framework of internal control requirements

Internal Controls

New standards that institutions should follow.   Internal controls seem to be the cornerstone of the new Uniform Guidance.  The phrase "internal controls" is repeated 103 times.

Procurement

Procurement requirements become more stringent for certain thresholds.  However, OMB has issued two announcements that permit institutions a grace period of two years for implementation.  As such, Dartmouth will continue to operate under the previous procurement standards while we monitor the situation.  

FAQ

110-6 Effective Dates and Grace Period for Procurement
Will the Federal government provide a grace period after the effective date for non-Federal entities to comply with the procurement standards in the Uniform Guidance?
Yes, for one full fiscal year after the effective date of the Uniform Guidance. In general non-Federal entities must comply with the terms and conditions of their Federal award, which will specify whether the Uniform Guidance applies. However, in light of the new procurement standards, for procurement policies and procedures, for the non-Federal entity's first full fiscal year that begins on or after December 26, 2014, the non-Federal entity must document whether it is in compliance with the old or new standard, and must meet the documented standard. For example, the first full fiscal year for a non-Federal entity with a June 30th year end would be the year ending June 30, 2016. The Single Audit Compliance Supplement will instruct auditors to review procurement policies and procedures based on the documented standard. For future fiscal years, all non-Federal entities will be required to comply fully with the uniform guidance.

From: The Federal Demonstration Partnership
Date:   Thursday, September 10, 2015


Colleagues,

As announced today in the Federal Register, https://www.federalregister.gov/documents/2015/09/10/2015-22074/universal-identifier-and-system-of-award-management-corrections (link is external), a second year has been added to the grace period for implementation of the Procurement Standards, 200.317 through 200.326, of the Uniform Guidance (UG). From the summary:

The Office of Management and Budget (OMB) is correcting the final guidance that appeared in the Federal Register on September 14, 2010 (75 FR 55673) and December 26, 2013 (78 FR 78589). OMB is amending the guidance to make technical corrections where needed. ...

Guidance on effective/applicability date is revised to allow a grace period of two fiscal years for non-Federal entities to implement changes to their procurement policies and procedures in accordance with guidance on procurement standards.

For an institution with a June 30th fiscal year-end, this means implementation is not required until July 1, 2017.

On behalf of the FDP membership, FDP leadership would like to thank those of you who participated in the surveys conducted to collect procurement data from your institutions. This data provided persuasive evidence that the procurement standards as currently written in the UG need further analysis and discussion. This was a very important factor in OMB's decision to extend the grace period because it provided data that showed the impact of the UG standards. We are hopeful that this extension to the grace period will allow for consideration of a more practical approach to ensuring procurement actions using federal dollars are reasonable.

Cindy Hope
Chair
Federal Demonstration Partnership

 

 Please monitor this website and OSP emails and newsletters as we release new highlights and information.

Government Sources:

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards:  The final "Uniform Guidance" 12/26/13

Chief Financial Officers Council COFAR

Frequently Asked Questions For The Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Office of Management and Budget website with links to the Guidance

Link to COFAR webcast on Uniform Guidance Implementation A Conversation Presented by the Council on Financial Assistance Reform, Thursday October 2nd, 1:00-3:00PM

Professional Organizations:

NACUBO

Grants Management Policy Page

NCURA

Videos from NCURA

 

 
 

Last Updated: 12/6/17