Recently, the Office of Management and Budget (OMB) released final guidance on “Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards.” This guidance, termed the “Omni-Circular” or “Uniform Guidance” combines eight previous circulars in an attempt to streamline policies and procedures for Federal awards into one place.
The new guidance will go into effect on December 26, 2014, with the exception of guidance on audit requirements, which will go into effect at the start of the institution’s fiscal year (July 1, 2015, for Miami University).
Just what the new guidance means for those who submit proposals and receive awards from Federal agencies is yet to be 100% determined, but we can expect some of the following changes.
Conflict of Interest
While a few of the Federal grant awarding agencies have conflict of interest policies in place, many do not. With the new guidance, all Federal agencies will be required to develop conflict of interest policies. Luckily for us, the practice of reporting potential and actual conflicts of interest is already in place at Miami University, so the new guidance should not affect our current practice beyond tweaking our current policy.
The new circular requires that Federal funding opportunities be announced 60 days in advance of due date. While some exceptions allow for a minimum of 30-days advance notice, we should see fewer “surprise” or last-minute announcements, allowing more time for proposal preparation. As always, advance notice to OARS is appreciated. In fact, we developed the External Proposal Submission Incentive (EPSI) Program to encourage an early heads-up to your OARS consultants.
Federal awarding agencies will be required to design and execute proposal review processes based on proposal merit. The nature of the review process will be left up to the individual agencies. Over the past couple of years, we have seen the National Institutes of Health (NIH) and the NSF (National Science Foundation) take a close look at their review processes, resulting in changes both review and scoring of proposals. Likely we will see other agencies follow suit.
Voluntary Cost Sharing
Recently, the NSF clamped down on showing voluntary (i.e., non-mandatory) cost sharing in a proposal in order to gain an “upper hand” in the review process. In the new circular, all Federal agencies are being required to crack down on voluntary cost share. The bottom line for grant writers: if cost sharing is not required, don’t include it!
In the past, Federal agencies could either let program income generated under a Federal award be used toward project costs –or- require that generated funds be returned to the Federal-awarding agency. In the new guidance, income from fees for services performed, from rental or personal property acquired under a Federal award or from the sale of commodities or items fabricated under a Federal awards (e.g., license fees and royalties on patents and copyrights) can be used to pay for current project costs or used to meet Federal cost share requirements.
Administrative and Clerical Support
Can Federal funds be used to pay administrative/clerical staff? “It depends,” was the previous answer to this question, and with the new circular little has changed. The new circular states that salaries for administrative and clerical staff may be allowable as direct costs in certain circumstances provided those costs are not being captured under indirect or facilities and administrative costs (F&A). Additionally, a specific individual must be identified and associated with specific work on a project in order to directly charge for clerical support. In our current negotiated indirect cost rate agreement, administrative and clerical support is captured as part of our F&A base. Therefore, the answer to “Can Federal funds be used to pay administrative/clerical staff?” is still “it depends” based on the nature of the project and the duties to be performed — contact OARS if you have questions.
F&A (Facilities & Administrative Costs)
Federal awarding agencies are now required under the new guidance to accept Federally-negotiated rates unless a particular funding program has a statutory rate. This means that our current F&A rate of 42% of modified total direct costs can be charged to a majority of our Federal sponsors. (And if we happen to be working with an entity that does not have a Federally-negotiated rate, the new guidance has set a rate of 10% of modified total direct costs for those entities.) Again, if you have questions, feel free to contact an OARS representative.
In the past, a computer or computing device had to be essential to the project (or research) being proposed and had to be 100% allocable and dedicated to the project. The good news is that while computing devices must still be essential and allocable, they do not have to be 100% dedicated to a project in order to be requested.
The new circular requires that all financial data (i.e., the budget and expenditures) be related to performance outcomes. Because of this new requirement, we may see some Federal agencies requesting budgets be based on performance indicators or milestones. Stay tuned…
In order to procure goods and services, institutions currently have to go through a competitive bidding process depending on the cost of the goods/services. The new guidance specifically lays out guidelines for procuring goods and services <$3,000, between $3,000 and $149,999 and >$150,000. If in doubt, contact Miami’s procurement office for guidance.
In the past, grantees had 90 days after the award end date to officially close out their grants (with both a technical and final, financial report). The close-out period has been extended to 120 days, but beware, as failure to close-out by the end of the 120 days could result in a loss of funds or future funding with an agency!
More to come
The Office for the Advancement of Research and Scholarship (OARS), along with Grants and Contracts, will be heavily monitoring the changes in the new guidance and reviewing and analyzing our existing policies and procedures to ensure we are in compliance with the new guidance. Any changes to our current policies and practices will be communicated to you, our constituents, via e-mail, this blog, and special training/education sessions.
Written by Tricia Callahan, Director of Proposal Development, Office for the Advancement of Research & Scholarship, Miami University.