Sponsored Research Administrative Guidance for Federal Research Awards - new OMB Uniform Guidance
The following information aims to help the campus stay informed about the progress being made in the implementation of the Uniform Guidance which will become effective December 26, 2014 for all new awards and funding increments. Additional information will be added as implementation of the Uniform Guidance becomes more explicit.
Office of Management Budget (OMB) background
Grants and contracts awarded by the federal government are subject to federal government administrative requirements, cost principles, and audit requirements. In the past, there were three OMB circulars that provided this guidance: A-110 (administrative requirements), A-21 (cost principles), and A-133 (audit requirements).
OMB has issued new guidelines for federal grants management through one “super” circular entitled, “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” This Uniform Guidance, designed to reduce the administrative burden on recipients of federal funds as well as the risk of waste, fraud, and abuse, will become effective December 26, 2014 for all new awards and funding increments.
What does this mean for Principal Investigators and academic departmental business administrators?
There are still many unanswered questions about how the federal agencies will interpret and implement the Uniform Guidance, and the federal agencies are asked to issue guidance in unison by December 26, 2014. Some of the new federal regulations will make grant management noticeably more flexible and efficient for our PIs and support staff. Other changes in sponsor requirements will require adjustments in our business processes. Not unexpectedly, some of the changes will make grant management more challenging, requiring more oversight and rigor on the part of UCSD researchers and administrators. There also will be situations in which no change will be needed in the way we manage grants and contracts.
Effective for federally funded sponsored research proposals and awards
Federally Funded Sponsored Research Proposals: Effective immediately, proposals submitted to federal sponsors should incorporate provisions of the Uniform Guidance, particularly in regard to administrative cost principles and inclusion of certain computing equipment.
Federally Funded Sponsored Research Awards: Uniform Guidance will generally be applicable to new awards and funding increments awarded on or after Dec. 26, 2014,
See a quick guide to major changes in the Uniform Guidance affecting proposal budgets and charging of direct costs.
Campus Wide Workgroup and coordination with UCOP and UC systemwide
UCSD has set up a campus-wide work group to coordinate implementation of the Uniform Guidance, with representatives from numerous administration offices. Our implementation efforts are expected to be aligned with the other UC campuses and the University of California. While policy direction may be provided by UCOP, our work group will address its own implementation issues, including policy development, process and system changes, and training to central administrators and fund managers. Following is a list of members:
- David Meier, Audit and Management Advisory Services
- Mark Cooper, Office of Post Award Financial Services
- Linda Collins, Office of Contract & Grant Administration
- Lynelle Gehrke, Office of Contract & Grant Administration
- Steve Carter, SIO Office of Contract & Grant Administration
- Todd Adams, Procurement & Contracts
- Maureen O’Connor, Health Sciences Sponsored Research Pre-Award Office
- Erika Wilson, Health Sciences Services Core
- Adam Diprofio, Jacobs School of Engineering
- Duyen Aller, Office of Post Award Financial Services
- UC San Diego campus notice from Vice Chancellor of Research
- UCOP Uniform Guidance website
- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (December 2013)
- Quick guide for PI's and administrators
Key topics and impact areas
- Proposal Development
- Cost Principles
- Close Out
- Subrecipients (subawards)
- Cost Share
- Effort Reporting