Uniform Guidance aka UG, UniGui HUGE: CSU Harnessing Uniform - - PowerPoint PPT Presentation

Uniform Guidance

aka “UG”, UniGui HUGE: CSU Harnessing Uniform Guidance Effectively

An update for SFSU Faculty and Staff

Uniform Guidance

Most significant change in research administration in 50 years

Uniform Guidance Reform History

• Nov. 2009:

Executive Order: Reduce Improper Payments Feb 2011: Presidential Memo: Reduce Administrative Burden Feb 2012: Advance Notice of Proposed Guidance (public comments) Feb 2013: Notice of Proposed Guidance (public comments) Dec 2013: Final Uniform Guidance

3

Uniform Guidance Timeline

Subpart 12/26/2013 Uniform Guidance published by Office of Management and Budget (OMB) Spring 2014 Federal Demonstration Partnership (FDP) and Council on Governmental Relations (COGR) present issues to OMB 5/9/2014 NSF published Draft Proposal and Award Policies and Procedures Guide (PAPPG) 15-1 6/26/14 Agency draft implementation guidelines due (none other than NSF submitted to date) 2/12/14 and 8/29/14 Council on Federal Assistance Reform (COFAR) publish FAQs 12/25/14 Research Terms and Conditions Expire 12/26/14 Agency Implementation Guidelines expected to be published ** COGR and FDP still working in include technical corrections and clarifications to FAQs

Uniform Guidance Goals

• Elimination of duplicative or conflicting guidance
• Focus on performance over compliance for accountability
• Encouraging efficient use of technology and shared services
• Provide for consistent and transparent treatment of costs
• Limiting allowable costs to make most efficient use of federal

resources

• Setting standard business processes using data definitions
• Strengthening oversight and internal controls
• Targeting audit requirements on risk of waste, fraud and abuse.

Uniform Guidance

• Use to refer to OMB (Office of Management and Budget)
• Circular A-110
• Circular A-21
• Circular A-133
• Now refer to Uniform Guidance: 2 CFR 200, Subparts A-F, Sections

100 through 500

• Over 100 pages long
• http://www.ecfr.gov

Big Picture

Award Terms and Conditions (incorporates the terms above) Program and Administrative Regulations (codified regulation such as UG, FAR and specific policy manuals) Legislation (Laws- Federal and State)

Uniform Guidance Outline

Subpart A- 200.XX Acronyms and Definitions B- 200.1XX General Provisions C- 200.2XX Pre-Award Requirements and Contents of Federal Awards D- 200.3XX Post Federal Award Requirements E- 200.4XX Cost Principles F- 200.5XX Audit Requirements Appendix I Funding Opportunities Appendix II Contract provisions Appendix III Indirect Costs (F&A)

Uniform Guidance Implementation

• Applies to new awards and funding increments awarded after

December 26th, 2014 (Happy Holidays!)

• New Procurement Standards will be deferred by one year grace

period- effective 7/1/2016

• Subpart F (Audit Requirements) will be effective July 1, 2015 for CSU

What has changed?

Subawards Administrative Salaries Computing Devices Publication Costs Travel Costs Cost Sharing Record Retention Close out Faculty Disengagement Visa Costs Conferences Procurement

Charging Administrative Salaries

What changed in UG?

A-21 Uniform Guidance Major Project Integral to a project or activity Definition of “integral”: in·te·gral ˈin(t)əɡrəl,inˈteɡrəl/ adjective

• 1. necessary to make a whole complete; essential or fundamental.

Allowable, Allocable, Reasonable….. Still apply! UG 200.413

New Rules for Charging Admin inis istrativ ive Sala laries

The salaries of Administrative and Clerical Staff should normally be treated as indirect (F&A) costs

Direct Charging of these costs may be appropriate of all of the following conditions are met:

• Administrative or clerical services are integral to a project or activity;
• Meaning that the services are essential, vital or fundamental to the project
• Individuals involved can be specifically identified with the project or activity;
• Such costs are explicitly included in the budget or have the prior written approval
• f the Federal funding agency;
• A budget justification must be included in the proposal,
• The costs are also not recovered as indirect costs

UG 200.413

SFSU Policy

• Federal Awards received prior to December 26th must continue to follow OMB A-

21 Guidance

• New Awards will follow the new Uniform Guidance
• Non-Federally Sponsored Projects
• Direct charging of administrative or clerical salaries to a non-federally

sponsored project may be appropriate if the services benefit that sponsored project.

• These charges need to be addressed in proposals

UG 200.413

Charging Computing Devices

What changed in UG?

A-21 Uniform Guidance Must be specifically tied to a project Now considered a “supply” Devices under $5,000 equipment threshold Essential and allocable, but not solely dedicated, to the performance of a federal award Allowable, Allocable, Reasonable….. Still apply! UG 200.453

New Rules for Charging Computin ing Devices to Sponsored Programs

• “Supplies means all tangible property other that those described in Section

200.33. A computing device is a supply if the acquisition cost is less than the lesser of the capitalization level established by the non-Federal entity for financial statement purposes or $5,000 regardless of the length of its useful life.

• Computing devices means machines used 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.

• Materials and supplies used for the performance of a Federal award may be

charged as direct costs. In the specific case of computing devices, charging as direct costs is allowable for devices that are essential and allocable, but not solely dedicated, to the performance of a Federal Award.

UG 200.453

SFSU Policy

• Federal Awards received prior to December 26th must continue to follow

OMB A-21 Guidance

• New Awards will follow the new Uniform Guidance
• Federal sponsors may impose requirements for these costs to be included in the

proposal budget, and may require a justification

• PIs will still need to provide a justification for these purchases and describe how these

are essential and allocable to the project

• Non-Federally Sponsored Projects
• Direct charging of computing devices to a non-federally sponsored project

may be appropriate if the devices benefit that sponsored project.

• These charges need to be addressed in proposals

UG 200.453

Charging Visa Costs

What changed in UG?

A-21 Uniform Guidance No guidance Costs associated with visas when critical skills are needed for a specific award may be proposed and charged as a direct cost Allowable, Allocable, Reasonable….. Still apply! UG 200.463

PI/Project Director Disengagement

What changed in UG?

A-21 Uniform Guidance Prior approval required for the absence

• f the approved PI or Project Director for

more than three months New language to reflect that PIs/ Project Directors can be away from campus and remain engaged in the project at the proposed and awarded levels UG 200.308

Prin incipal l In Investigator/Project Dir irector Dis isengagement

• For non-construction Federal Awards, recipients must request prior approvals

from Federal awarding agencies for one or more of the following program or budget-related reasons:

• (1) Change in scope and objective of the project or program (even if there is

no associated budget revision requiring prior approval)

• (2) Change in a key person identified in the proposal or the award
• (3) Disengagement from the project for more than three months, or a 25%

reduction in time devoted to the project, by the approved project director or Principal Investigator.

UG 200.308

Travel Costs

What changed in UG?

A-21 Uniform Guidance Airfare costs in excess of the customary standard commercial airfare (coach or equivalent), Federal contract airfare (where authorized and available), or the lowest commercial discount airfare are unallowable except….

• 1. Commercial airfare- least expensive

unrestricted accommodations

• 2. Family friendly policy allowing for

dependent care under specific and limited circumstances Under discussion with colleagues in the CSU and the Chancellor’s Office UG 200.474

Travel and Dependent Care Costs

• Commercial Airfare: least expensive unrestricted accommodations class
• ffered by commercial airlines
• Temporary dependent care costs (dependent defines in 26 U.S.C. 152) above

and beyond regular dependent care that directly results from travel to conferences is allowable provided that:

(i) the costs are a direct result of the individual’s travel on the Federal award; (ii) the costs are consistent with the non-Federal entity’s documented travel policy for all entity travel; and (iii) are only temporary during the travel period.

• Travel costs for dependents are unallowable, except for travel of duration of

six months or more with prior approval of the Federal awarding agency.

• See also section 200.432 (Conferences)

UG 200.474

New Rules on Cost Sharing

What changed in UG?

A-21 Uniform Guidance No prohibition on cost-sharing included in merit review of proposals Cost-sharing cannot be used during the merit review of proposals, unless specified in a notice of funding

• pportunity

NSF implemented guidance effective 1/18/2011 1/5/2001 Clarification on VUCS (Voluntary Uncommitted Cost-Share) included in FAQs still references A-21 1/5/2001 Clarification on VUCS (Voluntary Uncommitted Cost-Share) effective and references in A-21 VUCS: faculty effort that is over and above that which is committed and budgeted for in a sponsored agreement UG 200.306

Charging publications costs

What changed in UG?

A-21 Uniform Guidance Allowable if the costs were incurred in the period of performance Can charge anticipated publication charges that will occur outside the period

• f performance

UG 200.461 But how would this work??

Closeout

What changed in UG?

A-21 Uniform Guidance Final closeout within 90 days Final closeout within 90 days, both billing and performance reports No time limit on final billing UG 200.343

Closeout

• The non-Federal entity must submit, no later than 90 calendar days after the

end date of the period of performance, all financial, performance, and other reports as required by the terms and conditions of the Federal award

• The Federal agency or pass- through entity may approve extensions when requested by

the non-Federal entity

• Unless the Federal awarding agency or pass-through entity grant an extension
• The non-federal entity must liquidate all obligations incurred under the Federal award

not later than 90 calendar days after the end of the period of performance as specified in the terms and conditions of the Federal award.

UG 200.343

Record Retention

What changed in UG?

A-21 Uniform Guidance No guidance Allows for Electronic Record Retention UG 200.333 UG 200.355

Record Retention

• “The Federal awarding agency and the non-Federal entity should, whenever

practicable, collect, transmit, and store Federal award-related information in

• pen and machine readable formats rather than in closed formats or on

paper.”

• “When original records are electronic and cannot be altered, there is no need

to create and retain paper copies. When original records are paper, electronic versions may be substituted through the use of duplication or other forms of electronic media provided that they are subject to periodic quality control reviews, provide reasonable safeguards against alteration, and remain readable"

Procurement

What changed in UG?

A-110 Uniform Guidance General Procurement Standards Five methods of Procurement Many changes in UG, however, due to the grace period on implementation, SFSU will continue to follow OMB A-110, further clarification on UG will be provided at a later date. UG 200.317- 200.326

1. Micro- Purchases 2. Small Purchases 3. Sealed Bids 4. Competitive Proposals 5. Sole Source General Standards:

• A. Documented Policies
• B. Necessary
• C. Full & Open Competition
• D. Conflict of Interest
• E. Documentation
• i. Cost & PriceAnalysis
• ii. Vendor Selection

Procurement “Claw” (Sections 200.317-326)

1. Micro Purchases 2. Small Purchases 3. Sealed Bids 4.

Competitive Proposals

5. Sole Source

• $3K
• No quotations
• Equitable distributions
• Up to $150K
• Rate quotations
• No cost or price

analysis

• > $150K
• Construction

projects

• Price is a major

factor

• > $150K
• Fixed price or cost

reimbursement

• RFP with

evaluation methods

• Unique
• Public emergency
• Authorized by agency

(or PTE)

• No competition

Procurement “Claw” (Section 200.320)

Internal Controls

• 200.303 – Strong emphasis on internal controls
• Requires recipients to have strong internal controls;

should be in compliance with … COSO (Committee of Sponsoring Organizations) or the Federal “Green Book”

• Recent FAQ: there is no expectation or requirement

that internal controls be documented or evaluated prescriptively to these guidelines – use as a source for best practices

UG 200.303

Highlights of Key Changes affecting SFSU

• Procurement changes and the one year grace period (begin FY2016)
• Charging Computing Devices
• Charging Administrative and Clerical
• Internal Controls
• Performance Measurement
• Fixed Amount Sub-awards
• Sub-recipient Monitoring
• 10% de minimus F&A Rate for sub-recipients
• Effort Reporting

What do Faculty need to know?

New regulations and University policies on:

• Cost-sharing
• Direct Charging of Computing Devices
• Direct Charging of Administrative and Clerical salaries and wages
• Visa charges
• Travel and Dependent Care
• Publication Costs
• Subawards and Subrecipient Monitoring responsibilities
• 10% de minimus F&A Rate for sub-recipients
• Faculty Disengagement
• Procurement changes (one year grace period)