Effective December 26, 2014, the rules related to federally-sponsored awards have changed. These modifications are due to the federal government’s efforts to more effectively focus federal resources on improving performance and outcomes while ensuring the financial integrity of taxpayer dollars. The federal government is referring to this effort as the Uniform Guidance (UG). The guidance supersedes the requirements of various OMB circulars, including OMB Circular A-21, Cost Principles for Educational Institutions, and OMB Circular A-110, Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations.
Executive Summaries:
- Title change from “Policies Governing Subcontracts on Sponsored Projects.”
- UG revisions including updated terms and references to OMB Circulars.
- Expands subrecipient monitoring requirements.
- PTEs required to pay subrecipient invoices within 30 days unless deemed improper.
- Requires PTEs to honor the subrecipient’s negotiated indirect cost rate, negotiate a rate, or provide a minimum flat rate of 10%.
- Removed language addressing contracts (to be written).
- UG revisions including updated terms and references to OMB Circulars.
- Defines PI “disengagement,” previously referred to as “absence.”
- Title change from “Purchasing on Sponsored Projects.”
- Elects one year grace period for procurement standards set by UG.
- Improved content organization.