Those of you with Federal grants or contracts are used to seeing the instructions that you must conform to the Federal Office of Management and Budget (OMB) circulars such as A-133 and A-110. As of December 26, 2014 these and six other circulars have been superseded by an omni-circular, the Uniform Guidance (UG). Many of the prior requirements have remained in place; there are some important changes, especially in regards to making subawards to other institutions, and purchasing regulations (including paying consultants). These changes affect all new or continuation Federal grants and contracts dated 12/26/14 and beyond.
Please see the information below and if you have questions contact our office.
The New Guidelines
Government guidelines aren't fun to read, we know that. If you are senior personnel on a Federal grant/contract, or a subaward on such, you are responsible for knowing what the Uniform Guidance says. So here it is: Preamble and Subparts A-F.
The OMB has provided crosswalks and text comparisons between previous circulars and the Uniform Guidance: Policy Statements.
Important Changes to Know About
The Uniform Guidance was created to eliminate the redundancies and contradictory language among the previous circulars. The result of making everyone follow the same regulations is that other types of institutions (such as hospitals, tribal governments and non-profits) have to now conform to guidance we've always used; conversely, there are some requirements that other types of institutions have been using that now apply to us, as well as some new items for everyone. Here are select changes and where to find them in the UG:
- Administrative and Clerical salaries - now allowed on Federal projects if considered integral to the project itself (not just to general operations). See Sections 200.413 Direct Costs and 200.430 Compensation - Personal Services.
- Closeouts - all Federal sponsors are now required to stick to the 90 day closeout rule on awards; no more wiggle room. Be sure to provide our Finance office with all your expenses in a timely fashion at the end of your project. See Section 200.344 Closeout.
- Consultants and other contractors - while the language in the UG hasn't changed in terms of "professional services", the amount of money you can pay a contractor without having to fill out a sole-source justification has. For consistency's sake, such a justification will be required for all consultants regardless of cost. The Consultant Sole Source Justification and Independent Contractor Checklist are both found on our Forms page and must be submitted together, to OSP for review prior to sending to Accounts Payable. Please contact our office for guidance, and see Sections 200.459 Professional Service costs, 200.67 Micro-purchase and 200.320 Methods of procurement to be followed.
- Indirect Costs - with some exceptions, Federal sponsors are now required to use awardees' negotiated indirect cost rate(s). This also applies to subawardees under Federal awards. If a proposed subawardee does not have a negotiated rate, a de minimis rate of 10% on modified total direct costs should be used. See Section 200.414 Indirect (F&A) Costs.
- Subrecipient Monitoring - for greater transparency, the UG requires us to include more information about Federal awards to our subawardees. In addition, we are required to measure risk and monitor our subawardees more carefully to ensure that our Federal dollars are being spent responsibly. To assist you in this requirement, the Finance office has provided a Subrecipient Invoice Monitoring Guide, which must accompany all requests for payment to your subawardees, and can be found on our Forms page. See Section 200.330-332 Subrecipient Monitoring and Management.
- Procurement Standards - Delayed for some time, these standards have finally gone into effect and affect all purchases made on Federal awards here at Fordham as of July 1, 2018 (the start of Fiscal Year 2019). There are some changes to how you can purchase supplies and hire vendors. Please see the brief (<20 min) training video here for more information on these new requirements: https://youtu.be/bpfb5J5QqPQ