Fiscal Compliance Corner – Uniform Guidance Update MRAM October 2014 Ted Mordhorst Assistant Director for Post Award Financial Compliance Research Accounting & Analysis

Uniform Guidance UW Proposal Preparation Guidance released September 19th A short digest on some key costs and the associated requirements in order to include in a proposal budget Suggested budget justification language Cross-reference to pertinent section in Uniform Guidance

Uniform Guidance Highlights of costing policy changes: Admin and Clerical costs – Slightly less restrictive requirements to justify; see UG language However, when adding to a project and did not include in proposal, must seek prior approval from Sponsor Computing devices – Allowable but must be essential to project Short term visa costs – Allowable but must be critical and necessary Costing policy changes: Become familiar with the changes and be prepared to justify adequately in budget justification!

Uniform Guidance Other broad known changes: F&A is to be provided to all Subrecipients (de minimis 10% MTDC if no negotiated rate) Increased emphasis on Subrecipient Monitoring (centrally and by PI/dept) Increased emphasis on “Internal Controls” to prevent Fraud Waste and Abuse Voluntary cost-share cannot be part of the sponsoring agency’s funding consideration and sponsors cannot “encourage” it.

Uniform Guidance What we don’t know: What changes a specific agency may make. Other than NSF no agency implementation plans have been released. What impact the Procurement changes will make. Implementation of the procurement provisions have been delayed until July 1, 2016.

Uniform Guidance What the Uniform Guidance Core Team is engaged in: Drafting changes to the GIMS Drafting changes to web pages Drafting changes to training materials Providing information and communication to campus

GIM changes underway GIM #Current TitleTentative New TitleSubstantive Change due to UG GIM 2 Fiscal Responsibilities on Grant and Contract Accounts Acceptance of Sponsored Program Awards and Fiscal Responsibilities on Sponsored Program Accounts Integrate emphasis on internal controls GIM 7 Sponsored Program Subcontracts Policy Sponsored Program Subawards Administration Integrate new specific requirements related to F&A to subrecipients and pull out subrecipient monitoring detail (moved to new GIM) GIM 13 Facilities & Administrative Cost Rates No title change Limitations on when waiver will be granted when funding is federal, to be consistent with UG GIM 21 Cost Sharing Policy on Sponsored Agreements Cost Sharing Policy on Sponsored Programs Limitations on when voluntary cost- share allowed, to be consistent with UG GIM 23 Costing Policy for Sponsored Agreements Costing Policy for Sponsored Programs Integrate new benchmark for when administrative/clerical costs justified, and requirement for prior approval if adding after project started GIM 39 Closeout of Sponsored Programs No title change Broaden application of policy to fiscal and technical closeout requirements NEW GIM Subrecipient Monitoring N/AStatement of responsibility regarding monitoring subrecipient sponsored program activity, both centrally and by UW PI and department