It’s 2014! Our holiday wishes came true – at least some of them, any way. No shutdown in Washington D.C. – check. At the same time, Congress decided to roll back part of the sequestration cuts and restore funding to many areas of the Federal Government affected by last years deep spending cuts – check. And the Office of Management and Budget – gave us that mega-circular they had been promising for 2 years – CHECK!
That’s a Mouthful!
The new mega-circular, known as Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Final Rule, aims to tame the avalanche of overlapping or contradictory guidance that was previously in effect with the eight separate circulars published by the OMB over a series of many years. These circulars, (including A-133, A-21, and A-110) applied to hospitals, institutions of higher education, non-profit institutions, cities, states, tribal organizations, and other types of organizations, and over the years, interpreting the guidance in these documents became more difficult. A working group came together to combine the circulars into one document that would apply to all non-Federal agencies and aim to simplify the process of managing grants and contracts. These organizations worked with COFAR (the Council on Financial Assistance Reform) and the administration to develop new guidance that reflected the current reality of managing Federal awards.
The new guidance was published on December 26, 2013 in the Federal Register, and it’s over 100 pages long. It is well organized, easy to read and search online, and has a lot of familiar information for research administrators. However, in revising and updating the guidance for managing grants and contracts, the Federal government took the opportunity to incorporate input from organizations and change policies and processes regarding grants management.
What You Should Know
Key aspects of the new guidance include the following:
- Performance over Compliance for Accountability
The emphasis in the new guidance is definitely on generating results and outcomes that can be shared with other award recipients. The Federal government is not going to allow non-compliance, but they do not want overly burdensome rules to prevent an investigator or a collaborating team from accomplishing their research aims. As you read the guidance, you’ll see that this is the goal.
- Family-Friendly Policies Encouraged
The guidance definitely encourages organizations that receive Federal funding to develop (if they do not already have) family-friendly policies. They have updated their policies to include family-friendly issues such as costs related to the identification of day-care providers, and the need to allow parents to document time out of the workforce on their biosketches.
- Increasing de minimis Threshold for Indirect Costs to 10%
The new guidance allows organizations that cannot afford to negotiate an indirect rate to budget a 10% de minimis indirect rate with the Federal government. Previously the rate was 8%.
- Administrative Costs can be Charged as Direct Costs
The guidance also provides specific information, in many ways, for the first time, about how to manage administrative costs as a direct cost. This issue can be difficult because it is often charged as an indirect cost (an in most cases it should be charged that way). This guidance correctly acknowledges the need for charging administrative costs as a direct cost and how to manage this situation.
- Payment Management System Clues
The circular provides more information than before on ensuring consistency in allocating costs, and when to secure written approval for assigning a cost to an award. The cost principles and audit sections of the document are very useful, and it states that there is now a limit of three years for the Federal government to review awards in order to disallow costs. This, combined with the new 90 day rule for reporting on awards at the end of the project period gives us an indicator of how the Federal government will be managing award dollars in the future. Can you say “use it or lose it?”
- Focus on Delivering Results and Outcomes
There is an entire section in the document that discusses how RFAs and PAs will be written and what must be included in them. The circular states that RFAs and PAs have to be available 60 days before the opportunity closes – which is an interesting development. It will be fascinating to see if the language on “outcomes” and “milestones” translates into a new format for the funding announcements. Stay tuned.
To see a webcast about the new guidance click here.
Here’s to a great start to 2014 – may your New Year be productive and fulfilling!