About

On December 26, 2013, the Office of Management and Budget (OMB) issued the “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards,” or  Uniform Guidance (UG). The Uniform Guidance consolidated, streamlined and superseded eight OMB Circulars, including Circulars A-21, A-110 and A-133. The new guidance took effect on December 26, 2014.


Significant Changes


Administrative/Clerical Salaries

Can direct charge administrative/clerical salaries if they meet the following:


Computing Devices

Computing devices (laptops, desktops, software, etc.) NOT considered a depreciable asset by NC State University may be charged as supplies

Definition: 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.


Conferences

Very similar to A-21 with these additions:


Cost Share


Entertainment Costs

Costs of entertainment, including amusement, diversion, and social activities and any associated costs are unallowable.

UG Provides exception. If entertainment costs have a programmatic purpose and are authorized either in the approved budget for the Federal award or with prior written approval of the Federal awarding agency, the costs are allowable


Faculty Disengagement

The Uniform Guidance recognizes that PIs can be engaged in projects even if not physically on-campus.


Indirect Cost Rate – Federal Agency Recognition of Full Negotiated Indirect Cost Rates


Participant Support Costs


Prior Approvals – mentioned in multiple sections of the UG

These examples from the UG represent areas where Prior Approval is required. It is unclear at this time how individual Federal awarding agencies will incorporate them.


Subrecipient Monitoring and Management

Increased requirements for subrecipient review and monitoring


Subrecipient Indirect Cost Rate

Any non-federal entity (state, local government, Indian tribe, institution of higher education or nonprofit organization) that has never had a negotiated indirect cost rate may use a de minimis rate of 10% of modified total direct costs (MTDC) indefinitely. The only exception is a governmental department or agency unit that receives more than $35 million in direct Federal funding must submit an indirect cost proposal. This will allow very small entities to recover 10% of MTDC from the federal government to share in the cost of operations.


Travel


Visa Charges (under Recruiting Costs)

Short-term, travel visa costs (as opposed to longer-term, immigration visas) are generally allowable expenses that may be proposed as a direct cost. Since short-term visas are issued for a specific period and purpose, they can be clearly identified as directly connected to work performed on a Federal award. For these costs to be directly charged to a Federal award, they must:


Navigating the Uniform Guidance

For ease of navigation, the Uniform Guidance is broken down into its following subparts:

Preamble – Major Policy Reforms
Subpart A (200.0 – 200.99) – Acronyms and Definitions
Subpart B (200.100 – 200.113) – General Provisions
Subpart C (200.200 – 200.211) – Pre Award Requirements
Subpart D (200.300 – 200.345) – Post Award Requirements
Subpart E (200.400 – 200.475) – Cost Principles
Subpart F (200.500 – 200.521) – Audit Requirements (includes Appendices I-XI) – Subpart F will apply to audits of fiscal years beginning on or after December 26, 2014


Federal Agency Resources


NCURA Presentations