Federal Uniform Guidance ("Uniform Guidance") is the streamlining of administrative tasks as they relate to federal awards, such as grants and cooperative agreements.
Uniform Guidance allows the Government to be more efficient, effective, and transparent and also seeks to reduce waste, abuse, and burdens related to the administration of grants and other federal awards.
Under Uniform Guidance, estimated costs must be competitive and reasonable. Large, remaining balances will need to be returned to the Sponsoring Agency.
Notably, Uniform Guidance makes the application of federally negotiated F&A Rates mandatory by federal agencies and other flow-through entities, which are required to honor other entity's F&A Rates or the new 10% de minimis rate for entities without a rate agreement.
The following direct cost items have significant changes to the treatment when charging federal awards under the Uniform Guidance:
• Participant support: Clarifies the treatment and definition of participant support costs as costs for training or conferences for participants who are not employees. (no F&A)
• Computing devices: Classifies computing devices as part of materials and supplies. Now allows flexibility in charging these costs when they are necessary but not solely dedicated to an award.
• Administrative and clerical salaries: Removes the major project determination and allows for charging with prior approval when specific conditions are met.
• Compensation – personal services: Emphasizes internal controls in the standards for documentation of personnel expenses. Systems for documentation must provide reasonable assurance that charges are accurate, allowable and properly allocated.
• Publication and printing: Provides flexibility to charge publication costs incurred after the period of performance but before the final closeout of the project. (still must meet reporting deadline!)
Additionally, specific to Pre-Award functions, the following updates (12/26/14) should be taken into consideration:
- Administrative Salaries. Salaries and administrative staff may be charged to a federal grant IF (1) administrative staff is essential to the project; (2) administrative staff must be specifically included in the budget; (3) salaries must be explicitly included in in the budget; and (4) associated salary costs must not be subject to indirect costs.
- Computers. Computing devices not solely dedicated to th award costing <$5,000 may now be included as a direct cost as long as the computers are essential to the project and that they are not being purchased for convenience or preference.
- Participant Support. Some Federal Sponsors allow participant support if the PI obtains prior approval from the Sponsor. Line items may include: stipends/substience allowances, travel allowances, and registration fees.
- Short-Term Visa Costs. Short-term visas may be charged to a federal award if the individuals holding the visa are to receive salary from a federal award.
- F&A Rates. University/Higher Educational Institutions' federally-negotiated F&A rate must be accepted by all federal Sponsors.
- Fixed Price Subawards. Fixed price subawards are now subject to additional limitations and approvals and are limited to $150K.
The Office of the Federal Register: The Daily Journal of the United States Government's website provides more information relating to Uniform Administrative Requirements. Cost Principles, and Audit Requirements for Federal Awards.