PROPOSAL PREPARATION GUIDANCE

Costing Policy Changes under OMB’s new Uniform Guidance (UG),the “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards,” issued on December 26, 2013 by the Office of Management and Budget (OMB) supersedes the requirements of other OMB circulars, including Circular A-21 and A-110. The new federal requirements became effective beginning December 26, 2014, and apply to new awards and incremental/supplemental funding awards made on or after that date.

USU has assembled this proposal preparation guidance for used when developing budgets and documentation for proposals that were awarded on or after December 26th. As necessary, this matrix will be updated and other training materials will be made available to keep investigators informed about changes in USU’s internal control systems related to the UG.

Change / Standard / Actions at USU to comply / UG Section
Computing devices may be charged as direct costs under the UG under certain circumstances. Devices that meet USU’s threshold for capital equipment ($5,000) will be treated as such, and may not be charged as supplies. / To be included in direct costs, computing devices (and any peripherals) must be essential to perform the work, and allocable to the project. Budget justifications should provide support of these concepts, and should indicate that the project does not have reasonable access to other devices or equipment that could support these functions.Practices for purchasing computers at USU must be consistent across the institution. / Work with your Sponsored Programs representative when budgeting. / 200.20
200.33
200.94
Clerical & Administrative costs are allowable as direct costs under the UG as long as the individual’s responsibilities are “integral” to the work. / To be included as direct costs, it must be demonstrated that clerical & administrative personnel are “integral” or necessary to the project, and that the scope of work to be provided is unique and beyond the services normally provided to a research project by USU. Practices for charges of clerical and administrative salaries must be consistent across the institution. / Clerical and administrative salaries should be discussed with the Sponsored Programs representative. 1) Include as a line item any individual that is providing clerical/administrative support that meets the standard, 2) provide a description in the budget justification to support the individual’s role as being “integral” to the project, and 3) include clear indication of how the individual is identified as part of the project team. / 200.413
Effective July 1, 2016, procurement under federal awards must fit one of five categories. / Micropurchase limits will be set to $3,000 under the UG. This creates a gap between $3,000 and $5,000 that USU currently applies that will need to be addressed prior to the new requirements being implemented. Additional information will be provided as USU evaluates its procurement practices. / Work with Sponsored Programs Accounting (SPA) to identify areas where procurement practices may change over the life of the award. / 200.317
200.319
200.320
Notices of Funding Opportunities are required to be available for 60 days unless otherwise approved, and must include any mandatory cost sharing. Under the UG, mandatory and committed cost sharing must be included in the budget. / If required in the announcement, cost sharing must be included in the budget. However, if not required, cost sharing may not be considered in the merit review process. If cost sharing is not required, it will generally not be allowed except when a PI has not included any effort in the budget, requiring that some effort must be imputed to the award. / USU currently establishes cost matching accounts when a cost match is approved on a project. Expenditures in these accounts must be documented in a way that is consistent with documentation of expenditures of Federal funds. / 200.306
Monitoring and reporting program performance is expected to be outcomes based, requiring a risk assessment by USU and additional monitoring ofsubawardees. / The Sponsored Programs Division is implementing a new subrecipientrisk assessment that will require additional information to be gathered from subrecipients by both Sponsored Programs and by the PI. / PIs should coordinate with Sponsored Program and Sponsored Programs Accounting to provide the required level of monitoring and reporting under the UG. / 200.328
200.331
Close outs are expected under the UG in 90 days. / The importance of the long-standing 90-day closeout period has recently been increased by implementation at the agency level of new technology to more closely monitor costs on a project-by-project basis. If closeout is not achieved, payments from that agency may be withheld. / Begin coordinating early with your Sponsored Programs representative and SPA. / 200.343
The UG requires all agencies to recognize an institution’s negotiated F&A rate. This should include project in which USU is a recipient of federal funding through a pass-through entity. / USU will be seeking to leverage this guidance to recover a greater portion of the facility and administrative costs associated with its research. / Coordinate with your Sponsored Programs representative to include appropriate F&A costs in your budgets. / 200.414
Except when a federal agency is subject to a reduced F&A rate, the UG requires non-federal awardees to pay the approved F&A rate of subawardees. / Subawardees who do not have a negotiated rate with a cognizant federal agency will receive a 10% de minimus rate. USU will not negotiate rates with subawardees who do not have an established rate with the federal government. / Coordinate with your Sponsored Program representative to identify the appropriate subaward F&A rate to be included in the budget. / 200.331
200.414

January 13, 2015