Uniform Guidance Basics

On December 26, 2013 the Office of Management and Budget (OMB) released its final rule of “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (2 CFR Chapters I, II, Part 200, et al), and later provided interim updates.

This guidance to federal agencies consolidates and replaces eight OMB Circulars such as the A-110 (Administrative requirements), A-21 (Cost principles), and A-133 (Audit requirements). The Uniform Guidance (UG) applies to all new federal awards issued on or after December 26, 2014. Modifications adding new funding to awards issued prior to that date may also include a clause updating the terms of the award to fall under UG.

Federal agencies (NIH, NSF, Dept of Energy, etc) have each developed their own agency-specific implementation plans for the Uniform Guidance. The plans for some agencies adopt the Uniform Guidance in its entirety. Other agencies list specific exceptions. It is necessary to review the Uniform Guidance, the sponsoring agency’s implementation plan and the award terms to determine what rules will apply to any new federal funding.   

Note that Federal-wide Research Terms and Conditions (RTC), including waiver of prior approvals and other requirements, have now been finalized. Contact your OSP representative if you have any questions.

Timeline

  • December 26, 2013 – OMB issued the final rule of the Uniform Guidance (UG).
  • December 19, 2014 Joint Interim final rule published:  Includes OMB updates to UG and Federal agency-specific plans for implementing UG.
  • December 26, 2014 – UG went into effect. 
  • July 1, 2015 – Uniform Guidance audit requirements are applicable to MIT awards.
  • October 14, 2015 - Proposed Federal Research Terms & Conditions for the Uniform Guidance posted for public comment
  • March 14, 2017 – Federal Research Terms and Conditions and Prior Approval Matrix published.
  • July 1, 2018 – Uniform Guidance procurement requirements are applicable to MIT awards.

Agency Updates

NSF Proposal and Award Policies and Procedures Guide (PAPPG) (NSF 16-1) (final)

NIH Grants Policy Statement (final) 

MIT’s Working Group on Uniform Guidance

MIT has assembled a working group to review the new guidance and develop implementation plans. Contact the Uniform Guidance Working Group at uniform.guidance.team@mit.edu with your questions on the new Uniform Guidance.

Group members include:

Michelle Christy

Director, Office of Sponsored Programs

Michael Bowers

Associate Audit Director, Audit Division

John Donahue

Associate Director, Office of Sponsored Programs (Cost Analysis)

Robin ElicesExecutive Director, Office of the Executive Vice President & Treasurer

Anthony Flaherty

Assistant Director of Contracts, Vice President for Finance Office

Ron Hasseltine

Assistant Provost for Research Administration, Office of the Provost

Richard Lay

Special Projects Officer, Office of Sponsored Programs

Karon McCollinVPF-Administrative Services and Operations

Michael Moody

Institute Auditor, Office of the Executive Vice President and Treasurer

Gerard O’Toole

Director of Financial Operations, Vice President for Finance Office

Glen ShorVice President for Finance, Office of the Executive Vice President & Treasurer

Danielle Khoury

Controller, Vice President for Finance Office

Timothy VachaManager of Sponsored Accounting

Shawna Vogel

Associate Director, Office of Sponsored Programs (Grants and Contracts)

OMB Uniform Guidance: 2 CFR Chapters I, II, Part 200  (PDF, HTML)

Navigating the Uniform Guidance

Information can be found more easily by understanding that the Uniform Guidance is broken down into Subparts. The preamble also provides a useful framework and discussion of how certain guidelines were ultimately determined.

Preamble – Major Policy Reforms
Subpart A – Acronyms and Definitions
Subpart B – General Provisions
Subpart C – Pre Award Requirements
Subpart D – Post Award Requirements
Subpart E – Cost Principles
Subpart F – Audit Requirements

 

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