Uniform Guidance updates
Effective October 1, 2024
This document is a brief summary of the changes that most likely impact proposal and research sponsored project funds management at NAU. Please note not all changes will affect NAU (and many other institutions) until the next restatement of our negotiated indirect cost recovery agreement. The updated guidance can be found on Code of Federal Regulations (CFR) website.
Your pre and post award administrators are the best point of contact for any questions or concerns related to these updates.
Background
In October 2023, the Office of Management and Budget (OMB) announced revisions to uniform administrative requirements, cost principles, and audit requirements for federal awards – regarded as Uniform Guidance (UG). Since then, OMB has received extensive public comments and contributions from federal agencies providing revisions to streamline, clarify, and update the guidance. These changes represent the most substantial revision to UG since its inception in 2014.
Objectives
OMB provided four objectives surrounding the final revisions to the UG:
- Incorporate statutory requirements and administrative priorities.
- Reduce agency and recipient burden.
- Clarify sections that recipients and/or agencies have interpreted in different ways.
- Rewrite applicable sections in plain language — improving flow and addressing inconsistent use of terms.
Overview
Changes were applied for the following:
- Subpart A – acronyms and definitions (200.1)
- Subpart B – general provisions
- Subpart C – pre-federal award requirements and content of federal awards
- Subpart D – post federal award requirements
- Subpart E – cost principles
- Subpart F – audit requirements
Sponsor agency implementation plans
National Science Foundation (NSF) Accordion Closed
As part of its implementation strategy, NSF has archived the Research Terms and Conditions (RTC), and the NSF agency specific requirements. Unless otherwise specified, the Grant General Conditions (GC-1) apply to all recipients of NSF grant awards.
National Institutes of Health (NIH) Accordion Closed
As noted in NOT-OD-24-069, the Office of Management and Budget (OMB) has issued updates to 2 CFR Part 200, with an implementation date of October 1, 2024. NIH will include the changes to 2 CFR Part 200 in the FY 2025 release of the NIH Grants Policy Statement, in line with the implementation date set by OMB.
National Aeronautics and Space Administration (NASA) Accordion Closed
Applicants to NASA Notices of Funding Opportunity should be aware that grant awards made on or after October 1, 2024, must comply with new Title 2 regulations found at the Chief Financial Officers Council website (cfo.gov). The regulations posted on the Electronic Code of Federal Regulations website (ecfr.gov) will be updated October 1, 2024.