The University of Vermont

To:Principal Investigators & Business Unit Administrators

From:Jennifer Gagnon, Associate Vice President for Research Administration

Subject:Updateson Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Date:April 14, 2015

I am writing with some promisingupdates about the Federal agencies’ andUniversity’s implementation plans for the new Federal regulations that took effect on December 26, 2014.

Prior Approvals: As you know, the Uniform Guidance contains a number of new and continued prior approval requirements.For ease of understanding these requirements, SPA has created a reference grid, broken down by Federal agency,for the most commonly requested approvals. See the SPA Uniform Guidance site for details and below for important highlights:

1)Administrative Salaries are allowable as a direct charge on Federal projects as long as certain conditions are met, including prior approval from the sponsoring agency. The National Institutes of Health (NIH) hasdelegated this prior approvalauthority to the grantee institution. To that end, the process to request or charge administrative salaries on NIH proposals and awards is as follows:

  • When administrative or clerical salaries are considered integral to an NIH project, please complete the UVM Direct Cost Justification Form(DCJF).
  • Following approval of the DCJF and whenever possible, the administrative or clerical salaries should be included in the proposal budget and budget justification.
  • When administrative or clerical salaries are not included in the NIH proposal but are laterdetermined to be integral to the work, the DCJF must be submitted and approved by SPA prior to directly charging the effort. Sponsor prior approval is not necessary in these cases.

2)Travel on National Science Foundation (NSF) agreements no longer requires prior sponsor approval:

  • When known, all travel (domestic & foreign) and its relation to the proposed activities must be specified, itemized and justified by destination and cost in the proposal.
  • When travel is not included in the NSF proposal but is later deemed necessary to complete project aims, please notify the SPA Financial Analyst assigned to your departmentwith the same information for review and budget setup.
  • If a travel budget line is already established but additional travel becomes necessary to complete project aims, please continue to retain all documentation about the trip and its relation to the proposed activities.

Associate Vice President for Research Administration

340 Waterman Building

85 South Prospect Street, Burlington, VT 05405-0160

(802)656-3360 fax: (802)656-8604

Equal Opportunity/Affirmative Action Employer

The University of Vermont

3)Pre-Award Spendingrequires prior approval from the sponsoring agency to incur such costs, however some agencies have delegated this prior approvalauthority to the grantee institution. Please visit SPA’sPre-Award Spendingpage for the definition of “Pre-Award Spending,”the process to request prior approval by agency, and suggested language to include in a proposal budget justification when Pre-Award Spending is necessary or anticipated.

Subrecipient Monitoring: With the new requirement for institutions to document the review of subrecipient performance reports, SPA will now stamp the following certification on all final invoices from subrecipients for the Principal Investigator’s review and approval:

“Performance report deemed satisfactory and final invoice approved for payment”

Any final invoices received directly by the PI or Unit Administrator should have this same language added with the PI’s signature before sending to SPA for review and processing. Receipt, review, and documentation of acceptance of performance reports must be made before final payment can be issued.

Cost Policy Updates:The Uniform Guidance Costing Subcommittee will continue its work through the spring and plan to make revisions to the Cost Policy, which will go into effect on July 1, 2015. In the meantime, UVM has already implemented someof the flexibility afforded by the Uniform Guidance by allowing the direct charging of certain costs (such as Computing Devices). SPA can continue to answer any questions you may have on specific costs.

As always, we will continue to provide regular updates on this topic by memo and on the SPA Uniform Guidance website. Please also contact the SPA Research Administrator or Financial Analyst with whom you work for assistance.

Associate Vice President for Research Administration

340 Waterman Building

85 South Prospect Street, Burlington, VT 05405-0160

(802)656-3360 fax: (802)656-8604

Equal Opportunity/Affirmative Action Employer