A RAPid alert from the U-M OMB Guidance Task Force.
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OMB Uniform Guidance - December 2014 Update

What you need to know at the University of Michigan

As the year comes to a close we would like to let our University of Michigan community know that, for now, very little action needs to be taken to conform to the Office of Management and Budget's (OMB) new Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards," (also known as the Uniform Guidance, 2 C.F.R. § 200). 

For a year we have awaited the implementation date of December 26, 2014. However, to date only one agency -- the National Science Foundation (NSF) -- has published how it will implement the requirements of the Uniform Guidance. 

Here is what we do know to help you prepare: 

  1. Remaining Federal Agency Implementations* are expected to be released on December 18th.
  2. New Federal Research Terms & Conditions* are expected to be released in by early February (retroactive to December 26, 2014).
  3. A new Federal Award Identification Number (FAIN) in eResearch - ORSP will be entering this FAIN on Project Award Notices (PANs) and Project Award Changes (PACs) in eResearch, to comply with §200.210 (Information contained in a Federal award). No action needed by research administration community; we simply want you to be aware that, after December 26, 2014, you may start seeing the FAIN on PACs and PANs.
  4. NSF has released its Proposal Award Policies & Procedures Guide (PAPPG) - NSF 15-1revised this year to implement the Uniform Guidance. 
    • NSF will conduct an online webinar/training session covering the changes to their Proposal & Award Policies & Procedures Guide (PAPPG) on Thursday, January 15, 2015, at 2:00 PM. Registration is required. Please direct any questions to policy@nsf.gov, or (703) 292-8243. 
  5. Continue to do the following, as conveyed back in the September issue of The RAP :
    • Cost Principles (A-21) - Know that cost principles from OMB Circular A-21 have not changed. In the future, we will refer to A-21 as the "Uniform Guidance Cost Principles."
    • Administrative & Clerical Salaries - The rules governing the charging of administrative and clerical staff salaries have not materially changed, but must be explicitly included in your budget.
    • Computing Devices - Computing devices can be charged as supplies, but the rules governing their allowability and allocability have not changed.
    • Participant Costs - Participant support costs must be explicitly included in your budget and excluded from the Modified Total Direct Cost (MTDC) base for calculating Facilities & Administrative (F&A) costs.
    • Subrecipient Monitoring - Subrecipients may use an F&A rate of 10% MTDC or request to negotiate a rate with U-M if they do not already have a federally approved F&A rate.
    • Procurement Date: July 2016 -The effective date of the rules regarding procurement has been delayed to July 1, 2016.

*The U-M Uniform Guidance Task Force will review these documents in the coming weeks and will provide comprehensive training in anticipation of July 1, 2015 (i.e., the start of FY2016) being the earliest day for which compliance with the Uniform Guidance will be tested by our external auditors.

Stay tuned in the new year. There will be more to come as Federal agencies implement the Uniform Guidance. 

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