What is Uniform Guidance?
The Office of Management and Budget (OMB) previously had 8 Circulars related to grants management and proper spending of Federal funds. To streamline administrative efforts, Uniform Guidance (UG) replaces and consolidates those Circulars (OMB Circulars A-21, A-50, A-87, A-110, A-122, A-89, A-102, and A-133). In consolidating the Circulars, OMB also updated outdated requirements to ease administrative burdens. OMB created the Council on Financial Assistance Reform (COFAR), an interagency group, and delegated the responsibility to COFAR to lead the development of Uniform Guidance. The final UG rule was issued on December 26, 2013 with an implementation date of December 26, 2014.
What is UT’s involvement in Uniform Guidance?
UT continues to be involved with the Council on Governmental Relations (COGR) and the Federal Demonstration Partnership (FDP) in a collaborative effort to ensure universities’ concerns and needs are being addressed. Internally, the UT Controller formed a Uniform Guidance Working Group to revise UT fiscal policies to reflect changes. While making these updates, representatives from all campuses had the opportunity to talk through policies and actual practices across the university and improve fiscal policies in areas unrelated to the UG changes.
How does the Uniform Guidance affect me?
Many of the changes are administrative and may not change the way you conduct business daily. Here are some changes that could affect you and your federal awards or subawards:
- More time to prepare applications. The UG requires that federal agencies post funding opportunities at least 60 days before a deadline.
- More F&A recovery. Federal agencies must accept an institution’s negotiated F&A rate unless the head of the agency approves otherwise.
- Administrative expenses as direct costs must be approved by agency. If a proposal includes as a direct cost any item that appear to be administrative (F & A type expense, such as a computer or administrative salary), the budget justification should include a clear and detailed justification for including the cost.
- Procurement of Small Purchases, starting at $3,000, is a problem point. UG requires obtaining quotes for purchases $3,000 to $149,999. UT and most other organizations have a higher limit than $3,000, so this adds an administrative burden. COGR is fighting this requirement. Fortunately, implementation of this requirement has been delayed.
- More subrecipient information. Subrecipients will be subject to a risk assessment, so more information will likely be required from potential subrecipients at the time of proposal submission and award. More reporting may also be required of subrecipients.
When will the Uniform Guidance apply?
The Uniform Guidance administrative requirements and cost principles apply to new and incremental funding awarded after December 26, 2014. Federal awards that were in existence at that date continue to be governed by the terms and conditions under which they were awarded, unless officially amended by the federal sponsor.
Who can I contact if I have questions about Uniform Guidance?
For any questions about UG, you may contact the UTIA Office of Sponsored Programs at 865-974-7537 or firstname.lastname@example.org.
What other resources are available related to Uniform Guidance?
Uniform Guidance Tools
Determination Guide for Agreements with External Entities/Individuals
Subrecipient Risk Assessment for New Subrecipients
Direct vs Indirect Charging Tools
Uniform Guidance PI Quick Guide to Exceptions
Direct vs F&A Charges Guide
Unallowable Costs Guide
UT Justification Samples Example Guide
Uniform Guidance (2 CFR 200)
Uniform Guidance FAQ
Council on Financial Assistance Reform (COFAR)
COGR Guide to Uniform Guidance