Uniform Guidance Information

Updated: 9/1/2015

The office of Management and Budget (OMB) issued the Uniform Guidance to supersede OMB Circulars A122, A110 and A-133 for Federally Sponsored Agreements and new funding increments incorporating the Uniform Guidance awarded on or after December 26, 2014.

NOTE: OMB Circulars A-122 and A-110 are still in effect for Federally Sponsored Agreements awarded prior to December 26, 2014.

The Uniform Guidance issued by the White House Office of Management and Budget (OMB) includes revised cost principles for all federal awards made on or after December 26, 2014.  This Cost Principles Reference Guide highlights select items of cost that should be considered in the budget preparation process and post‐award management, in accordance with the Uniform Guidance.  This guidance to federal agencies consolidates and replaces eight OMB Circulars such as the A-110 (Administrative Requirements), A-122 (Cost Principles), and A-133 (Audit Requirements)

The Uniform Guidance places strong emphasis on internal controls to reduce the risk of waste, fraud, and abuse in the stewardship of federal funding.  Internal controls are the organizational processes we implement to ensure operational effectiveness and efficiency, reliability of internal and external reporting, and compliance with applicable laws and regulations.

MBL is required not only to have effective internal controls, but to communicate and follow them.  We must also monitor compliance and take action when we identify issues.  PI’s, Center Administrators, and central offices will need to collaborate to meet those requirements.  This will include stronger efforts to limit cost transfers and late salary transfers, to practice effective financial review and control throughout the award period and to adequately document transactions.

The table below provides a summary of the most significant items of cost that have changed as a result of the Uniform Guidance.  Federal agencies continue to roll out their specific guidelines implementing the Uniform Guidance.  Agency guidelines may deviate from the Uniform Guidance and generally take precedence.  As agency guidelines become available, they are being added to MBL’s Uniform Guidance section of the OSP website.

Description Guidance Guidance
Administrative and Clerical Salaries Can be charged directly provided they are integral to the project’s objectives and detailed in the budget justification If you did not propose administrative/clerical salaries check to see if sponsor approval is required.
Computing Devices
(under $5,000/unit)		 Defined as supplies and allowable as a direct cost if essential and allocable, but solely dedicated to the project provided they are essential and allocable to the project. Computing devices should be itemized in the detailed budget justification.
Conferences Attendees from outside the MBL may charge the cost of identifying, but not providing, locally available dependent-care resources to a federal award. Prior approval from the sponsor is required if you did not propose administrative salaries for the identification of locally available dependent-care resources.
Cost Sharing Cost sharing on a Federal Award will not be a factor during the merit review except when allowed by a FOA. NSF prohibits cost sharing unless in the solicitation.

Participant Costs

 Participant Costs are excluded from MTDC and now universal across all agencies. Funds provided for participant support typically may not be used for other categories of expense without Sponsor prior approval Participant cost should be kept separately in financial system.
PI Absence from Project New guidance acknowledges that a PI can be absent from the campus and remain engaged in the project. A decrease in effort by 25% or more on a project requires prior Sponsor approval.
Publication

Publication Costs can be charged during closeout period.

MBL will need adequate time to close awards and all charges must be incurred during the first 60 days following the end date of the Sponsored Project award before closeout.

Short-term Travel and Visa Costs

Short term travel including H-1 and J-1 visa costs can be a direct charge when critical skills are demanded for a specific project.

Long term visa costs (green cards) are not allowable as a direct cost on a Federally Sponsored Award.

Individual Memberships

Individual Memberships are not an allowable direct cost on a Federally Sponsored Project.

Do not propose or charge individual memberships (business, technical, professional or personal).
Subawards

Uniform Guidance increases subrecipient monitoring, limits each fixed price subaward to $150,000, and provides a 8-10% de Minimis indirect cost rate if the subrecipient does not have a negotiated rate.

The de Minimis rate of 8 -10 % indirect costs applies to Foreign Subrecipients as well.
Closeouts

Final financial billing must be completed and submitted to the sponsor within the 90-120 day closeout period per Award Conditions. To closeout subawards insure they invoice promptly.

If requesting a NCE, please do so promptly. Review the terms and conditions of your award for number of days to closeout.

 

Overview of Key Principles

For any cost to be allowable under a federal award, it must:

  1. Be necessary and reasonable for the performance of the award and allocable thereto;
  2. Conform to any limitations or exclusions set forth in applicable regulations or in the award itself;
  3. Be consistent with policies and procedures that apply uniformly to both federally‐financed and other MBL activities; and
  4. Be accorded consistent treatment

“Direct costs” are those costs that can be identified specifically with a particular sponsored project or other internally or externally funded activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy.  In contrast, “indirect costs,” or facilities and administrative (F&A) costs are those, such as building operations and maintenance, administrative personnel and systems, and other similar costs, that benefit many activities. Costs incurred for the same purpose in like circumstances must be treated consistently, as either direct or indirect costs.

Uniform Guidance Sections:  200.403, 200.405 and 200.413.

Items requiring prior approval must specifically be requested in the proposal budget, or, must be requested in writing before the proposed change by the SRO in the Office of Sponsored Programs.

Full text of the Uniform Guidance can be found here.
Part 200 Cost Principles can be found here.
Frequently asked question on Uniform Guidance from the Office of Management and Budget can be found here.