Uniform Guidance: Executive Summary

The Uniform Guidance (2 CFR 200)

The Office of Management and Budget (OMB) combined many Federal circulars–including OMB Circulars A-110, A-21, and A-133–into a single document called the "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards," generally referred to as the Uniform Guidance or 2 CFR 200. The Uniform Guidance applies to new and incremental Federal awards issued on or after December 26, 2014.

Following are some key sections of the Uniform Guidance:

 

Cost Sharing

The Uniform Guidance states in 200.306 that voluntary committed cost sharing is not expected under Federal research proposals and cannot be used as a factor during the merit review of the proposal. Cost sharing may only be considered when required by regulation and transparent in the notice of funding opportunity.

 

Administrative/Clerical Staff
 

Administrative and clerical salaries should not generally be charged to sponsored programs unless all of the following criteria are met (§ 200.413(c)):
(1)    Administrative or clerical services are integral to a project or activity; 
(2)    Individuals involved can be specifically identified with the project or activity; 
(3)    Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and 
(4)    The costs are not also recovered as indirect costs.

Please complete the Cost Justification Form on proposals where administrative and clerical salaries are being direct charged to provide the justification and documentation required to support our decision to direct charge these costs.  There should also be an explicit explanation in the budget justification of the proposal.

 

Computing Devices

General purpose computing devices can be direct charged as a supply cost. §200.94 clarifies that a computing device is a supply, provided the acquisition cost is less than $5,000. This does not mean, however, that a laptop or IPad can be charged to every funded project.  A computing device will only be an allowable expense if it is necessary, reasonable, consistently treated, and properly allocated (see §200.403 and §200.405).

In plain language, this means the computing device must be: 

•    essential for the purposes of carrying out a specific aim of the funded project, 
•    above and beyond what is normally provided by the department for academic use, and 
•    charged to the grant in some reasonable proportion relative to how much it is used for the funded project.

PIs and departments should maintain documentation that describes how the proposed computing device meets the above requirements. Use of the Cost Accounting Justification for Non-Personnel Costs is recommended as a best practice. 

 

Travel Costs

 According to Uniform Guidance 2 CFR 200.474, an individual's travel can only be paid on a federally-sponsored award if the participation of the individual is necessary for the award and the costs are a direct result of the individual's travel for the federally sponsored award. Documentation should be maintained clarifying why the particular person is traveling, why the travel is necessary and how it benefited the project.