New Uniform Guidance

Uniform Guidance is the largest regulatory revision research administration has seen in recent years.  Grants and contracts awarded by the federal government to Radford University are subject to administrative requirements, cost principles, and audit requirements.  The new consolidated guidance replaces three Office of Management and Budget (OMB) Circulars governing those requirements applicable to universities and other related institutions.

The purpose of Uniform Guidance is to reduce the regulatory and administrative burden on funding recipients, as well as diminishing the risk of waste, fraud, and abuse. New and incrementally-funded awards issued on or after December 26, 2014 are subject to Uniform Guidance.  

The most current Code of Federal Regulations can be found at:

Electronic Code of Federal Regulations

Uniform Guidance is broken down into the following subparts:

Subpart A

200.000 – 200.99

Acronyms and Definitions

Subpart B

200.100 – 200.113

General Provisions

Subpart C

200.200 – 200.212

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

Specifically, for managing federal grants and contracts, the following subparts are very important to use as general guidance for grant accounting.

Subpart D  

Supplies

200.314

If there is a residual inventory of unused supplies exceeding $5,000 in total aggregate value upon termination or completion of the project or program and the supplies are not needed for any other Federal award, the non-Federal entity must retain the supplies for use on other activities or sell them, but must, in either case, compensate the Federal Government for its share. This is not a new requirement and existed under Circular A-110, C.35(a).

Subrecipient Monitoring

200.331

Institutions are required to perform a risk review of subrecipients prior to issuing a subaward. Potential items for review: financial and performance reports, audit deficiencies, indirect cost rate, training, and on-site visits.

Closeout

200.343

Closeout reports are to be submitted no later than 90 calendar days after the end date of the performance period.

Subpart E

Administrative & Clerical Salaries

200.413

 

Administrative and clerical staff should normally be treated as indirect (F&A) costs. Direct charging of these costs may be appropriate only if all of the following conditions are met:

 

  • Administrative or clerical services are integral to a project or activity;
  • Individuals involved can be specifically identified with the project or activity;
  • Such costs are explicitly included in the budget or have the prior written approval identified with the project or activity;
  • The costs are not also recovered as indirect costs.

 

Computing Devices

200.453

Computers under the university capitalization threshold may be charged as direct costs if they are essential and allocable, but not solely dedicated to, the performance of a federal award.

Publication and Printing Costs

200.461

Page charges for professional journals are allowable when they report work on an award and the journal levies charges impartially on all items published by the journal (whether or not under a federal award). The costs of publication or sharing of research may be charged even if incurred after the end date of the award but before award closeout.