University of Vermont

Sponsored Project Administration - SPA

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Omni Guidance Oct 2014

OMB Uniform Guidance - updated on April 13, 2015

The Office of Management and Budget issued new guidance for managing Federal sponsored activity. “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Final Rule. ” This is effective December 26, 2014 and replaces all governing circulars, including A-21, A-110 and A-133. 

The guidance impacts the daily administration of sponsored projects at all institutions of higher education that conduct federally-sponsored research, including UVM. The major focus areas are effort reporting, costing (direct and indirect), fringe benefits, procurement, subrecipient monitoring, and prior approval requirements.

UVM's Implementation of the OMB Uniform Guidance 

  • In preparation for the December 26, 2014 implementation date, UVM formed a steering committee to analyze the guidance and determine focus areas for the University.
  • The steering committee is led by Jennifer Gagnon, Associate Vice President for Research Administration, and Claire Burlingham, University Controller, with representation from Sponsored Project Administration, Cost Accounting Services, Procurement Services and Compliance Services.
  • Over the past several months, the steering committee has identified and grouped the highest priority components of the guidance, which were reviewed in depth by subcommittees comprised with representatives from central administrative offices and academic units.
  • Each subcommittee is led by a member of the steering committee and is responsible for determining the impact of the new regulations to existing policy and process, creating new training materials and revising policies and procedures where needed.
  • The subcommittee work is being kicked off in October with primary assessment results returned to the steering committee by mid-November 2014.

OMB Uniform Guidance Implementation Project: Kick-off & Updates

  • October 9, 2014 - Subcommittee kick off meeting - For more information about the committee charges, please review the presentation here - Powerpoint     pdf

  • December 17, 2014 - Subcommittee meeting to share the work of their colleagues and learn more about implementation priorities - Powerpoint     pdf

Subcommittee Membership*

*Committee chairs are identified in bold. 

  • Steering Committee - Jennifer Gagnon, Claire Burlingham, Sudha Ramaswami, Mike Meunier, Renee Hunt, Erica Heffner, Brian Cote, Natalie Guillette, Nick Brightman
  • Costing Subcommittee - Mike Meunier, Sudha Ramaswami, Rose Feenan, Eric Gagnon, Jana Talcott
  • Effort Subcommittee - Mike Meunier, Gina Bailey, Linda Burnham, Brian Cote, Doug Dickey, Skip Fanus, Jennifer Gagnon, Erica Heffner
  • Benefits Rates Subcommittee - Mike Meunier, Claire Burlingham, Alberto Citarella, Carrie Hopkins, Jana Talcott
  • Procurement Subcommittee - Natalie Guillette, Bridget Carney, Skip Fanus, Erica Heffner, Lana Metayer
  • Subrecipient Subcommittee - Nick Brightman, Natalie Guillette, Marcy Whittle
  • Communications and Training Subcommittee - Renee Hunt, Renee Berteau, Pam Blum, Emily Stebbins-Wheelock, Russell Tracy, Ph.D.

Project Timeline

  • October 9, 2014 - Kick-off; Subcommittees begin meeting
  • November 14, 2014 - Subcommittee impact and gap assessments due
  • November - December - Steering Committee prioritizes implementation requirements
  • December 26, 2014 - UG effective date; Begin implementation of priorities
  • January 31, 2015 - Subcommittee proposed implementation plans due
  • Spring 2015 - Continue implementation
  • June 30, 2015 - Implementation complete (for all but procurement requirements)
  • June 30, 2016 - Implementation complete for procurement requirements

Implementation

While the Uniform Guidance takes effect on December 26, 2014, UVM recognizes that it can not fully implement all necessary policies and procedure changes immediately to align with it. To that end, the subcommittees have made recommendations to the Steering Committee on the most urgent priorities and identified conservative alternatives for the remaining items pending full implementation. The urgent priorities and process changes to comply with them are detailed below.

Costing (Direct and Indirect)

The costing changes included in the Uniform Guidance offer some new flexibility around the direct charging of some costs, for example administrative salaries and computing devices, and in some cases, have also created additional administrative work.

 Administrative salaries are allowable as a direct charge to federal projects, as long as the following conditions are met:

    • Administrative or clerical services are integral to a project or activity;
    • Individuals involved can be specifically identified with the project or activity;
    • Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
    • The costs are not also recovered as indirect costs.
  • When administrative salaries are considered integral to a project, investigators must continue to complete the Direct Cost Justification Form, describing the integral nature of the administrative or clerical staff member’s effort is to the work of the project.
  • When integral to the work, administrative or clerical salaries must be included in the budget and budget justification of the proposal. Please note that the Direct Cost Justification Form must be submitted and approved by SPA staff prior to proposal submission.
  • When administrative or clerical salaries are not included in the proposal but are determined later to be integral to the work, prior approval from the sponsor is required before directly charging the effort. Prior approval must be obtained either via annual progress reports or via separate letter to the sponsor’s administrative office. See below for additional details.

Computing Devices are now classified under materials and supplies and may be directly charged to a sponsored project if the following conditions are met:

  • Devices are essential to the project; and
  • Allocable to the project.

Note that the devices need not be solely dedicated to the performance of the federal award in order to be directly charged.

  • Note that the request for computing devices should be included in the proposal budget and budget justification to the extent possible.
  • Investigators must continue to complete the Direct Cost Justification Form to describe the essential nature and allocability of the computing device prior to charging it to the project.

Participant Support Costs are excluded from the modified total direct costs beginning on December 27, meaning that these costs are no longer subject to F&A.

  • SPA staff will make the necessary adjustments to existing project budgets and new award budgets as appropriate.
  • Investigators and SPA staff must ensure that F&A is not included on participant support costs in future proposals.

Subrecipient Monitoring

There are two important changes to the issuance and monitoring of subrecipient activity, resulting from the Uniform Guidance and identified as priorities by the sub and steering committees:

  • UVM must offer its subrecipients of Federal funds a deminimis F&A rate of 10% if the recipient does not already have a Federally-negotiated rate. UVM will alert subrecipients of this option via the Subrecipient Commitment and Audit Certification Form completed by all proposed subrecipients during proposal development.
  • UVM must now document the review of subrecipient performance reports. Working with investigators, SPA will include in subaward agreements the explicit requirements for subrecipient completion of final performance reports. When reviewing the final invoice from the subrecipient, UVM PIs will confirm their receipt of the subrecipient performance report and approve the final subaward invoice for payment at the same time, noting that the “Performance report deemed satisfactory and final invoice approved for payment.”

Requests for Prior Approval & Associated Requirements

The Uniform Guidance outlines many new circumstances under which sponsor prior approval is required, including the following:

  • Pre-Award spending
  • No-Cost extensions (even first time occurrences), and
  • Direct charging of administrative or clerical salaries

Sponsor prior approval remains required for a number of other additional circumstances, including:

  • Change in scope of work;
  • Disengagement of the PI or key personnel for more than three months; and
  • Reduction in effort of the PI or key personnel by more than 25% of the commitment.

Sponsor prior approval may be sought via a formal request to a sponsor’s administrative contact and sometimes via a regular performance reporting to the sponsor. As a reminder, all requests for prior approval must conform to the sponsor’s specific requirements and follow the same procedure:

  • Requests must be reviewed by SPA and endorsed by an Authorized Institutional Official (typically the Director of SPA or Associate Vice President for Research Administration) prior to submission to the sponsor;
  • Requests must be submitted to the sponsor’s administrative contact;
  • Sponsor approval must be received prior to the requested action taking place.
On Dec 19, 2014, the Department of Health and Human Services (DHHS) issued their guidance and have clarified that, barring any other restrictions in the award document, for research SNAP awards prior approval is not required for
  1. Pre award costs up to 90 days before the start date of the grant
  2. One time no cost extension
  3. Carry forward unobligated balances to subsequent periods of performance, if the award document allows it.
This will allow us to continue with business as usual for our NIH and other DHHS awards.

Other

As noted above, the Uniform Guidance also focuses on a number of other areas, including effort reporting, fringe benefits, and procurement. The procurement requirements will become effective on July 1, 2016. The federal government published the interim final guidance on December 19, 2014. Stay tuned for additional information on these and other topics.

Resources

Please continue to check this website for updates as the committees continue their work.

Last modified April 14 2015 11:04 AM

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