Major changes in the Uniform Guidance affecting proposal budgets and charging of direct costs
The Office of Management and Budget (OMB) has combined many federal circulars into a single guidance document (known as Uniform Guidance, or 2 CFR 200) that can be used by all agencies. These new regulations became effective December 26, 2014 for all federal assistance awards.
Administrative and clerical salaries Accordion Closed
Applicable Uniform Guidance (UG) sections: 200.413, 200.430
The salaries of administrative and clerical staff should normally be treated as indirect 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 of the federal awarding agency
*Integral is defined as essential to the project’s goals and objectives, rather than necessary for the overall operation of the institution.
You may not include the salaries of administrative personnel conducting such activities as financial reconciliations, general office clerical work, and proposal preparation, as these costs must be recovered through F&A charges.
Examples of projects where administrative and clerical costs could be included as direct costs in a proposal, with proper justification, include, but are not limited to:
- Large, complex programs, such as program projects, centers, and other similar sponsored projects
- Projects with complex project management requirements, e.g., managing multiple sub-awards
- Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences.
Costs for developing and maintaining human or animal research protocols, managing substances and chemicals, securing project-specific data, or coordinating research subjects, are not considered “administrative and clerical.” The aforementioned costs may be directly charged to a project without obtaining prior approval, provided that they are directly related to work under a federal award and meet all the standard costing requirements.
The budget justification for any award seeking to charge salaries of administrative and clerical staff must include a narrative that explains how the services are integral to the project.
Computing devices (under $5,000 unit cost) Accordion Closed
Applicable UG section: 200.331
Computing devices under $5,000/unit may be direct charged to the project or activity under the following circumstances:
- 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.
- The project does not have reasonable access to other devices or equipment that can achieve the same purpose; devices may not be purchased for reasons of convenience or preference.
- Items costing more than $5,000 per unit are considered equipment and follow federal equipment rules for when they can be direct charged. (Refer to 200.33, 200.48, 200.89, 200.439)
*PIs are responsible for determining whether or not the device is “essential” and to what extent the cost of the device is allocable to the sponsored project. PIs and departments should maintain documentation that describes how the proposed computing device meets the above requirements.
F&A budget for sub-awards Accordion Closed
Applicable UG section: 200.31
Under the Uniform Guidance, Facilities & Administrative (F&A) costs must be budgeted for sub-recipients as follows:
- If the sub-recipient has a federally negotiated F&A rate, the negotiated rate must be included in all proposed sub-awards.
- If the sub-recipient does not have a federally negotiated F&A rate, the Uniform Guidance requires the use of at least a 10% de minimis F&A rate, except where the sub-recipient is able to allocate and charge 100% of its costs directly.
It is not permissible for the PI/department to force or entice a proposed sub-recipient without a negotiated rate to accept less than the de minimis rate. Finally, there is no change to NAU’s recovery of its own F&A costs – this remains limited to our F&A rate on the first $25,000 of each sub-award.
Participant support costs Accordion Closed
Applicable UG section: 200.456
Under the Uniform Guidance, other federal sponsors also may allow PIs to budget and charge for participant support costs. Participant Support costs include: stipend or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conference or training projects. Participant Support Costs are not routinely allowed on research projects but can be charged if the project includes an education or outreach component and the federal agency approves such costs.
These costs must be explicitly listed in the proposal budget (and budget justification) or approved by the funding sponsor after the award has been made. Participant Support Costs should be excluded from the Modified Total Direct Cost (MTDC) base when calculating F&A costs when the University’s federally negotiated F&A rate is applied.
PI Disengagement Accordion Closed
Applicable UG section: 200.308
Under the Uniform Guidance, prior sponsor approval must be obtained from the federal agency if the PI will be “disengaged” from the project for more than three months or if there is a 25 percent reduction in the time the PI devotes to the project. Note: PIs should work through OSP to formally obtain this approval from the sponsor.
“Disengagement” is defined as the PI no longer assuming primary responsibility for (a) the performance of the activities for which the award is granted and/or (b) compliance with the terms and conditions of the award, including but not limited to monitoring project expenditures, oversight of Sub-recipient performance and use of federal flow through funds, and preparation of any technical, progress or narrative reports required by the award.
Note: physical absence from the University campus is not automatically considered disengagement as long as the PI is able to carry out his or her PI responsibilities from a remote location.
Publication and printing Accordion Closed
Applicable UG section: 200.461
According to the Uniform Guidance, page charges for professional journal publications are allowable when:
The publications report work supported by the federal government and the charges are levied impartially on all items published by the journal, whether or not under a federal award.
The University may charge the federal award before closeout for the costs of publication or sharing of research results if the costs are not incurred during the period of performance of the federal award. However, these costs must be recorded/appear as a encumbrance on the general ledger within the 90 day closeout period, except for NIH and NSF in which case these costs must be recorded within the 120 day closeout period.
Sub-awards Accordion Closed
Applicable UG sections: 200.331, 200.305, 200.201, and 200.339
It is the PI’s responsibility to monitor the performance of any sub-recipient receiving funding from the PI’s federal award. Monitoring may include reviewing the sub-recipient’s financial and programmatic reports and, when appropriate, evaluating the sub-recipient’s completed milestones and deliverables. PIs are required to carefully review the sub-recipient’s performance in these areas before signing any invoice authorizing payment of funds to a sub-recipient.
Note: the Uniform Guidance requires the University to pay sub-recipient invoices, for cost reimbursable sub-awards, within 30 days of receipt of the approved invoice in Disbursements, unless the PI believes the request to be improper. PIs should notify his/her Fund Manager as soon as possible if a sub-recipient’s performance or invoice for payment does not conform to the terms and conditions of the sub-award.
Under the Uniform Guidance, the University must require the Sub-recipient of a fixed amount sub-award to certify at the end of the sub-agreement that the project or activity was completed or that the level of effort was expended as specified in the sub-agreement. If the Sub-recipient cannot certify that the required level of activity or effort was carried out, the University must adjust the amount of the funds paid to the Sub-recipient.
Under the Uniform Guidance, it is the responsibility of the University PI to monitor the activities of Sub-recipients to ensure that federal funds issued to the Sub-recipient are used for authorized purposes in compliance with laws, regulations, and the provisions of sub-agreement and that the performance goals are achieved.
NAU Policy; NAU Subrecipient Monitoring Policy
Voluntary cost sharing Accordion Closed
Applicable UG section: 200.306
Under the Uniform Guidance, voluntary committed cost sharing should not be expected by a federal sponsor or used as a factor during the merit review of applications or proposals, but may be considered if it is both (a) in accordance with federal awarding agency regulations and (b) specified in a notice of funding opportunity.
Since the federal agencies cannot consider voluntary committed cost sharing in assessing a proposal’s merit, voluntary committed cost sharing will not increase the likelihood of an award.
- Office of Management and Budget (OMB)
- Council on Financial Assistance Reform (COFAR)
- Council on Governmental Relations (COGR)
- 2 CFR 200: Uniform Guidance (12/2013)
- 2 CFR 200: Joint Interim Final Rule Implementing the Uniform Guidance (12/2014)
- COFAR UG Frequently Asked Questions (9/2015)
- NIH Frequently Asked Questions (2/2015)
- NSF Frequently Asked Questions (Updated 4/2015)
- NCURA FRA: Overview of the OMB Circulars (including the Uniform Guidance for Financial Administrators)