SHEILA T. LISCHWE, PH.D. OFFICE OF SPONSORED PROGRAMS UNIFORM GUIDANCE WORKING GROUP Uniform Guidance: What is the Impact at CU?

What is the Uniform Guidance? OMB Initiative to reduce duplication and administrative burden by combining federal regulations between 8 OMB circulars into one “supercircular” Governing Body – Council on Financial Assistance Reform (COFAR) Membership includes reps from NSF, NIH and other major agencies

Motivating Factors Federal Demonstration Partnership (FDP) Surveys – 2007 & 2012  42 percent of investigator time spent on administration National Science Board Report on Reducing Administrative Burden (2014)  Roundtables and potential solution

Timeline Released December 26, 2013 Agency implementation plans due to OMB by June 26, 2014 Regs effective December 26, 2014 Agency regs released 12/19/14

Overarching Approach Reduce administrative burden on investigator Ensure against waste, fraud and abuse Increased focus on “Internal Controls” within an institution  Policies and procedures  Strategies to identify ways to deflect and detect potential abuse of federal funds

Key Changes Administrative support allowable as direct cost with prior approval Computing devices now allowable Voluntary cost-share prohibited Full F&A negotiated rate encouraged Publication Costs allowed after end date Coverage of short-term visa costs

Administrative Salaries as DC “Integral” to the project  Definition: essential to completeness Must be included in proposal budget or have prior approval from agency Named personnel CU will require strong budget justification to prove “integral” nature of position to project

Computing Devices Allowable as a direct cost if they are essential and allocable but not solely dedicated to the performance of a federal award.

Computing Devices What is essential?  necessary to acquire, store, analyze, process, and publish data and other information electronically, including accessories (or “peripherals”) for printing, transmitting and receiving, or storing electronic information no reasonable access to other devices or equipment that can achieve the same purpose; devices may not be purchased for reasons of convenience or preference. PIs and departments should maintain documentation that describes how the proposed computing device meets the above

Voluntary Cost Share/Full F&A Cost share cannot be used as a factor in merit review process Full, negotiated rates encouraged Agencies can make exceptions to the above if it is clearly delineated in the solicitation

Publication Costs The non-Federal entity may charge the Federal award before closeout for the costs of publication or sharing of research results if the costs are not incurred during the period of performance of the Federal award. May see a cutoff threshold implemented: e.g. End date + 60 days BREAKING NEWS: Closeout in 120 days?

Short Term Visa Costs Must be for a specific period and purpose Typically J-1 and H-1B Not allowable: – premium or expediting processing fees – renewal application fees - institutional charge for processing - dependent application/processing fees

Other Administrative Changes Standardization of G.g. forms – no agency-specific forms allowable without OMB approval 60 day notice for RFPs Fixed Price Subawards up to $150k Prior approval for faculty disengagement for three months or effort reduced by 25%

Challenges How will OIG interpret and audit against the new regs? Will operate under 2 sets of regs 90 day auto closeout Measuring Performance  Progress report reminders & completion assurances  PI Certification  Subrecipient Performance

What is CU doing to prepare? UG Working Group  GCA (post-award)  OSP Pre-Award  HR, Payroll, Compensation  Provost’s Office  Controller’s Office  Internal Audit  Procurement  Faculty Senate/FS Research Committee

CU Preparations Critical Issues Template  What policies/procedures need to change? Following Lead of Professional Associations Updating OSP Certification Program Letter from Provost