Uniform Grant Guidance (2 CFR, Subtitle A, Chapter II, Part 200 Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards) Better known as the “UGG”

Streamlining was the Goal: Code of Federal Regulations under Title 34- Education Removed : Part 80 Uniform Requirements for Grants & Cooperative Agreements to State & Local Governments Removed: Part 74 Administration of Grants & Agreements with Institutions of Higher Education, Hospitals & Other Non-Profit Organizations Updated: Parts 75, 76, 77 & 81 to incorporate the changes. Streamlined the requirements from a number of OMB Circulars (A-21, A-87, A-110, A-122, A-89, A-102, A-133 and parts of A-50)

Streamlines guidance for Federal awards to ease the administrative burden. Strengthen oversight of Federal funds to reduce risk of waste, fraud and abuse. Increased focus on performance outcomes. Applicable to new awards made after 12/26/14– begins with Perkins 7/1/15 2 CFR Grants and Agreements- Part 200 (UGG)

Highlights: Heavier emphasis on the pass –through entity (ADE) to monitor performance and not just compliance (d) Will continue to be looking at both fiscal and programmatic activities. Multiple mention of performance, program outcomes and productivity as a major focus area.

Highlights: A non-Federal entity may charge to the Federal award only allowable costs incurred during the period of performance (unless given special permission for pre - award costs) Period of performance for Perkin’s is generally July 1 through September 30 Cannot obligate (order) in one fiscal year and liquidate (pay) in another. May have implications for travel and payroll

Highlights: Non-federal entities hosting or sponsoring a conference may include meals unless further restricted by the conditions of the federal award U.S. Department of Education grants have a very difficult burden to prove the allowability of food. See specific guidance: “Frequently Asked Questions on Using Funds for Conferences and Meetings” December,

Highlights: Time & Effort Previously (A-87 Circular) required: Semi-Annual Certifications for employees that work for a single cost objective. After the fact recording Account for total activity Signed by employee and supervisor Every six months Personnel Activity Report (PAR) for employees that work on multiple cost objectives. After the fact recording Account for total activity Signed by employee Prepared at least monthly and coincide with one or more pay periods.

Highlights: Time & Effort per new UGG Requirements (i): Less prescriptive rules- significant flexibility in adopting own processes. Charges accurately reflect work performed. Supported by a system of internal controls providing assurance charges are accurate, allowable and properly allocated. Incorporated into the official records Reasonably reflect total activity Encompass all activities (federal and non-federal) Comply with standard accounting practices/policies Able to support distribution among specific activities or cost objectives. If current system meets more stringent requirement, recommend maintaining.

Highlights: Procurement Changes Micro-Purchases Acquisition of supplies or services not to exceed $3,000 Award without competitive quotes Distribute equitably among qualified suppliers Small Purchase Raises the purchase acquisition threshold Goods & Services that cost less than $150,000

Highlights: Supplies- Computing Device Considered a supply if cost is less than $5,000 regardless of the length of its useful life. Inventory management– regardless of cost, must maintain effective control and safeguard all assets to ensure they are used for the authorized purpose. Equipment- Replacement Equipment (c)(4) When acquiring replacement equipment, can trade-in or sell the property and use proceeds to offset cost of replacement property.

Highlights: Change to Audit Requirement Non-Federal entity that expends $750,000 or more during fiscal year in Federal awards must have a single or program audit. Reminders: Record Retention Requirements Records for Federal awards maintained for three years from the date of approval of the Completion Report If litigation, claim or an audit is started before three years expires, must continue retention until resolved. Entertainment Costs Unallowable unless have a programmatic purpose and are authorized in approved budget or prior written approval.

Marilyn Gardner CTE Fiscal Director