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RSP News

Uniform Guidance Information


On December 26, 2013, the Office of Management and Budget (OMB) published, in the Federal Register, a document entitled the “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards”, 2 CFR 200.  As the name implies, this document, aka, Uniform Guidance, the Omni Circular, the Omni Guidance, is intended to streamline and promote consistency in the administration of Federal Awards (e.g., grants, contracts) across all Federal agencies.  As such, this Uniform Guidance replaces eight (8) OMB/guidance circulars currently in use.  Of particular interest to administering grants/contracts through Wright State (and by extension, to Wright State investigators), the Uniform Guidance will replace:

  1. A-21 (Cost Principles for Educational institutions),
  2. A-110 (Uniform Requirements for Grants & Agreements w/IHE, Hospital, & Mom-profits,
  3. A-133 (Audits of States, Local Governments, & Mom-profit Organizations, and
  4. A-50 (Single Audit Act Follow-up).

As this list indicates, the potential impact to Wright Stat faculty and staff on acquiring and administering grants and contracts extends form the planning stage (Pre-award) through the close-out stage (Post-award) and all points in between (e.g., Purchasing, Inventory, etc.).

The effective date by which these regulations must be in place for administering new awards is December 26, 2014.

[Currently OMB circulars No. 1, No. 2, & No. 3 may be found on RSP’s home page at Federal Laws and Regulations and OMB circular, No. 4 (A-50), can be found at this link and will remain available at these sites after December 26, 2014] 

To facilitate the transition, Wright State has several groups working through the Uniform Guidance to determine precisely what changes will need to be made to their policies and procedures to assure compliance.  A ‘Working Group’ of staff having expertise in all areas of Federal award administration was assembled to critically review the Uniform Guidance and a ‘Steering Committee’ was appointed to assist with, and assure the development and implementation (D&I) of updated P&P’s (written & physical, as necessary).  To date, the Working Group has completed their review of the Uniform Guidance and a list of recommendations has been submitted to the Steering Committee which is reviewing the recommendations and formulating action plans for implementation.

For the general information of faculty and staff, the following Uniform Guidance resource links are available for your review:

2 CFR 200 (Uniform Guidance)

  1. Preamble - Major Policy Reforms
  2. Subpart A (200.0 - 200.99) - Acronyms and Definitions
  3. Subpart B (200.100 - 200.113) - General Provisions
  4. Subpart C (200.200 - 200.211) - Pre-award Requirements
  5. Subpart D (200.300 - 200.345) - Post-award Requirements (including Close-out)
  6. Subpart E (200.400 - 200.475) - Cost Principles
  7. Subpart F (200.500 - 200.521) - Audit Requirements (Includes Appendices I - XI)

             [Note – Subpart F will apply to audits of Fiscal Years beginning on or after December 26, 2014.]

Office of Management and Budget (OMB)

  1. Uniform Guidance Crosswalk from Guidance to Existing Guidance – This document correlates individual UG sub-citations with existing OMB circular citations.
  2. Uniform Guidance Crosswalk from Existing Guidance to Final Guidance - This crosswalk highlights policy changes, clarifications, and updates to policy provisions from previous OMB circulars to the UG

 

Council on Financial Assistance Reform (COFAR) – COFAR provides FAQ’s, training webcasts and other resources in support of the conversion to UG.  Below are three (3) selected links.

1.   COFAR Home Page
2.   COFAR FAQ's - February 12, 2014
3.   COFAR FAQ's - August 29, 2014

Council on Governmental Relations (COGR) – COGR is involved in the development of all major financial and administrative aspects of federally-funded research.  

1.   COGR Home Page
2.   COGR Guide to 2 CFR 200 (April 24, 2014)

National Council of Research Administrators (NCURA) – NCURA is a professional organization that advances the field of research administration, in part, through education and professional development programs.

1.   NCURA National Home Page
2.   NCURA Uniform Guidance Videos

Additional Site(s) of Interest

1.   NSF's Proposed Policies and Procedures Draft

Training Materials

1.  Uniform Guidance: Summary of Changes to Federal Guidelines Affecting Wright State University (presentation to Business and Finance Officers, December 8, 2014)



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