Interim joint final rule from Federal Register, 2014-12-19 (pdf) This includes guidance from each major federal agency about implementation.
New Mexico State University UG Implementation Communications
On January 26, 2015, the university community received a communication from the Provost concerning recent changes to federal regulations governing the awarding, expenditure, and audit of federal awards. Following are specifics of the implementation of five changes with broad impact; these are effective immediately. Changes relating to procurement policy have a delayed implementation (July 2016) and will be communicated when they are effective.
Procedures for implementing each of the major changes affecting faculty and staff engaged in federal awards are being disseminated by the Office of the Vice President for Research; all these procedures will be available through the research tab at my.nmsu.edu (click on the Uniform Federal Award Guidance icon) and on the research website.
Section 2 CFR 200.305 requires the federal government and pass-through agencies to make payment within 30 calendar days after receipt of an invoice, unless the entity reasonably believes the invoice to be improper. Specifically, the university must make payments to subawardees within 30 days of the receipt of an invoice. To facilitate meeting this requirement, investigators should immediately review and approve any subawardee invoice received and forward to SPA for payment as soon as feasible; PI review of invoices is an existing requirement (not changed by the Uniform Guidance), ensuring that subawardee charges are appropriate.
200.314 Residual Inventory of Supplies
Section 2 CFR 200.314 states that “if there is a residual inventory of unused supplies exceeding $5,000 in total aggregate value upon termination or completion of the program and the supplies are not needed for another Federal award, the non-Federal entity must retain the supplies for use in other activities or sell them, but must in either case, compensate the Federal government for its share.”
Unused supplies exceeding the threshold of $5,000 in total aggregate value must be reported on the Report of Final Expenses. This form is prepared and submitted by a department, college, or unit as part of the award closeout process. Section 5 has been added to the form for this purpose.
If the residual supplies are to be used on a continuing award or other federally-sponsored activities, the first-in, first-out inventory should be used. That is, supplies transferred at the conclusion of another award should be used before using those purchased under the new award.
Modifications to section 3.15.15 of the NMSU Business Procedures Manual to reflect this requirement are in process.
NOTE: Pay special attention to computing devices. One interpretation may be that once a computing device is used on a project, it does not meet the definition of “residual inventory” and therefore is not subject to the post-award accounting requirement. However, proper cost allocation principles apply, and allocation may be questioned for computing devices purchased towards the end of a project.
§200.413 (c) Direct Charging of Administrative/Clerical Costs
Section 2 CFR 200.413 (c) allows charging administrative and/or clerical services as a direct charge to federal awards under specified conditions:
- The services are integral to the project or activity;
- Individuals involved can be specifically identified to the project or activity;
- Costs are explicitly included in the budget and/or have prior written approval from the sponsor; and
- Costs are not also recovered as indirect costs.
The Office of Grants and Contracts requires that all administrative and/or clerical costs to be included as direct charges to federal awards clearly meet the above criteria. Written justifications must be submitted to OGC at the proposal stage; if an unsolicited award is received, the justification must be submitted at the award stage.
§200.453 (c) Purchase of Computing Devices
Section 2 CFR 200.453 (c) allows purchase of computing devices as a supply cost when essential and allocable, but not solely dedicated, to a federal award. The Office of Grants and Contracts (OGC) requires that all computing devices to be purchased under a federal award are clearly justified as essential and allocable to the funded effort. Written justifications must be submitted to OGC at the proposal stage; if an unsolicited award is received, the justification must be submitted at the award stage.
§200.461 Publication and Printing Costs
Section 2 CFR 200.461 allows the charging of publication costs for electronic and print media, including distribution, promotion, and general handling as a direct charge to a federal award. Page charges for professional journal publications are allowable if the following conditions are met:
- The publications report work supported by the federal government;
- The charges are levied impartially on all items published by the journal, whether or not sponsored by a federal award; and
- Charges to the federal award may be made after the period of performance but before the award closeout.
The Council on Financial Assistance Reform (COFAR) site has links to video trainings on the uniform guidance, to the slides used in those trainings, and to updated frequently asked questions about the guidance released 2015-09-09. (Description of changes in the third release of the FAQ; full text: 2014-11-26. Earlier versions were released 2014-02-12 and 2014-08-29.) Supporting materials from OMB include text comparisons and crosswalks from current guidance to the uniform guidance.
Sections of the OMB Uniform Guidance Implementation video:
- Opening Remarks, 2016-07-05 (video)
- Risk Assessment, 2016-07-05 (video)
- Contract v Subaward Determination, 2016-07-05 (video)
- Sub-Recipient Monitoring, 2016-07-05 (video)
- Personnel Services, 2016-07-05 (video)
- Indirect Cost Rates, 2016-07-05 (video)
- Single Audit and CAROI, 2016-07-05 (video)
- Closing Remarks, 2016-07-05 (video)
Sections of the OMB Uniform Guidance Webcast video:
- Opening Remarks, 2014-10-02 (video)
- Internal Controls, 2014-10-02 (video)
- Procurement Standards, 2014-10-02 (video)
- Single Audit Reporting, 2014-10-02 (video)
- Administrative Flexibility and Performance Reporting, 2014-10-02 (video)
- Indirect Cost Rates for Subrecipients, 2014-10-02 (video)
National Science Foundation (NSF) Materials
National Institutes of Health (NIH) Materials
OMB Uniform Guidance - What it Means for NIH & You (Notice NOT-OD-15-077, 2015-03-06)
NIH Implementation of Uniform Guidance, 2015-03-02 (video)
NIH Implementation of Uniform Guidance, 2015-03-02 (ppt)
Council on Governmental Relations (COGR) Materials (COGR is a national organization of research universities with at least $15 million in annual research funding, and their affilated research foundations.)
June meeting Uniform Guidance related presentations, 2015-06-10:
- Costing Policies panel/presentations:
- Grant Closeout, NIH Subaccounting, and Payment Management System, 2015-06-04 (pdf)
- Considering Compensation -- Carefully, 2015-06-04 (pdf)
- Costing Policies Committee Update -- F&A, 2015-06-04 (pdf)
- Midterm report card on Uniform Guidance presentations:
March Meeting Report excerpts regarding Uniform Guidance, 2015-03-18 (pdf); related meeting presentations:
- F&A and the Uniform Guidance, 2015-03-05 (pdf)
- Uniform Guidance--F&A Pools, 2015-03-05 (pdf)
- UG, Compensation, personal services (§200.430) , 2015-03-05 (pdf)
- NSF: Challenges, Opportunities, and Implemenation of Uniform Guidance, 2015-03-05 (pdf)
- NIH Implementation of Uniform Guidance, 2015-03-05 (pdf)
- NIFA Implementation of 2 CFR Part 200 (Uniform Guidance), 2015-03-05 (pdf)
National Council of University Research Administrators (NCURA) Materials (NCURA is a professional organization comprised of university research administrators.)
Webinar, 2014-05-14 (slides pdf)
Video highlights from the webinar:
Related NCURA videos:
Moss Adams UG Resources Page (Moss Adams is a public accounting firm.)
most recent page update: 2016-07-06, recent material in boldface type