The Uniform Guidance (“UG”) is the single biggest regulatory change in the last fifty years of research administration. This guidance to federal agencies consolidates and replaces eight Office of Management and Budget (OMB) Circulars. It combines those circulars for Institutions of Higher Education--A-110 (Administrative requirements), A-21 (Cost principles), and A-133 (Audit requirements)--with those companion circulars applying to state and local governments, Indian tribal governments, and non-profits.
The UG came about as a result of President Obama’s February 2011, directive to OMB to reduce unnecessary regulatory and administrative burdens. In October 2011, OMB created the Council on Financial Assistance Reform (“COFAR”). This is an interagency group which includes OMB, HHS, NSF, COGR, and others. Their activities include providing recommendations to OMB on actions necessary to effectively deliver and oversee grants and cooperative agreements.
On December 26, 2013, OMB released its final rule of “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (2 CFR Chapters I, II, Part 200, et al). The implementation date for this regulation is December 26, 2014 for all parts except for those relative to audit requirements. Federal agencies (NIH, NSF, Dept. of Energy, etc.) must develop their own agency-specific policies that conform to the Uniform Guidance. Existing Federal awards will continue to be governed by their original terms and conditions. Once the Uniform Guidance goes into effect, it will apply to awards or funding increments issued on or after that date.
St. John’s University must adopt the new regulations and agency policies, and therefore must review its current policies and procedures to ensure they are consistent with the new guidance. We will modify our policies and procedures as necessary and use this new regulation as an opportunity to update our existing practices. Our plan is to work together across all campuses on this initiative.
The Uniform Guidance is broken down into Subparts. The preamble also provides a useful framework and discussion of how certain guidelines were ultimately determined.Preamble – Major Policy ReformsSubpart A – Acronyms and DefinitionsSubpart B – General ProvisionsSubpart C – Pre Award RequirementsSubpart D – Post Award RequirementsSubpart E – Cost PrinciplesSubpart F – Audit Requirements
Prior to implementation of the Uniform Guidance on December 26, 2014, each federal agency is required to finalize an agency implementation plan with OMB.
The National Science Foundation (NSF) released a draft version of their Implementation Plan for the OMB Uniform Guidance on May 9th. The draft version of the NSF PAAP Guide can be accessed at the following link:
National Science Foundation draft version
Other agency plans will not be available until shortly before the implementation date.