Federal Uniform Guidance

On December 26, 2014, the White House Office of Management & Budget (OMB) released new federal regulations: "Uniform Administrative Requirements, Cost Principles, & Audit Requirements for Federal Awards."

The new federal regulations supersede the requirements of previous OMB circulars, including:

  • OMB Circular A-21: Cost Principles for Educational Institutions
  • OMB Circular A-110: Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, & Other Non-Profit Organizations
  • OMB Circular A-133: Audits of States, Local Governments, and Non-Profit Organizations
How to determine if new guidance applies to award funding?
  • Old guidance applies to awards, renewed awards, and supplements dated prior to December 26, 2014.
  • New guidance applies to awards, renewed awards, and supplements dated on or after December 26, 2014.
Key elements with the implementation of the Federal Uniform Guidance (list in not all inclusive)
  • Administrative and clerical salaries may be allowable as direct costs if work is necessary for the project and sponsor specifically approves the cost. The following is the criteria that should be used to justify direct charging of these costs.
    1. Administrative or clerical services are integral to a project or activity;
    2. Individuals involved can be specifically identified with the project or activity;
    3. Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
    4. The costs are not also recovered as indirect costs.
  • Computing devices under $5,000 can be directly charged to grants if they are essential and allocable to complete the project work, even if they are not solely dedicated to the project. The following are specific circumstances under which direct charging of computing devices are allowable
    1. The machines are essential and allocable to the project in that they are necessary 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.
    2. The project does not have reasonable access to other devices or equipment that can achieve the same purpose; devices may not be purchases for reasons of convenience or preference.
  • Final progress, financial and other reports are due no later than 90 calendar days after the end date of the period of performance.
  • Participant support costs are exempt from F&A and require agency approval prior to inclusion in the budget and to re-budget for other purposes.
    1. Participant support costs include direct costs for stipends or subsistence allowance, travel allowances, and registration fees paid to or on behalf of participants or trainees (not employees) in connection with conferences or training projects.
  • Costs of publication or sharing of research results may be charged to the project even after the end of the award period, but must be recorded as an expense within 90 days of the end date of the award.
  • Sub-recipients are entitled to receive their federally negotiated F&A rate or a 10% de minimis rate if they do not have one, unless the Federal award restricts the F&A rate.
  • Short term visa costs are allowable under certain conditions, but long term (immigration) visa costs are unallowable.
    1. Visa issued for a specific period and purpose, and clearly identified as directly connected to work performed under the program. The cost must be critical and necessary for the conduct of the project and be allowable by the agency as well as consistent with the cost principals.
  • Procurement Standards have become more stringent which will have an effect on how purchases are made using grant funding. There is a new Micro-purchase threshold which is currently set at $3,000. The expectation is that any purchase equal to or exceeding $3,000 will require informal quotes or bids. This will have an impact on purchasing of goods and services and usage of the P-card.
    1. OMB has granted a one year grace period for the implementation of the Procurement Standards. The new Standards will become effective July 1, 2017 for NDSU.



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