1. Uniform Guidance 2 CFR 200 October 8, 2014
Sherry Esham Director, Sponsored Projects Services University of Arizona
Jeff Ratje Assistant Dean, Finance and Administration University of Arizona

2. Uniform Guidance 2 CFR 200
The goal of Uniform Guidance is to reduce administrative burden and risk of waste, fraud, and abuse.
2 CFR 200 replaces:
A-110* Admin Requirements
A-21* Cost Principles
A-133* Audit
A-102 Admin Requirements
A-87 Cost Principles
A-122 Cost Principles
A-89* CFDA
A-50 Audit Followup

3. Eliminate duplicative and conflicting guidance
Uniform Guidance 2 CFR 200
Objectives:
Eliminate duplicative and conflicting guidance
Focus on performance over compliance for accountability
Encourage efficient use of information
Provide for consistent and transparent treatment of costs
Limit allowable costs to make best use of Federal resources
Set standard business processes using data definitions
Encourage non-Federal entities to have family-friendly policies
Strengthening oversight
Target audit requirements on risk of waste, fraud, and abuse

4. Effective Dates
Uniform Guidance was issued on December 26, 2013 with an effective date of December 26, 2014 for non-Federal entities.
For new awards and for incremental funding awarded on or after December 26,2014
Federal agencies should complete their implementation guidelines on or before December 26, 2014
The audit requirements will be effective for non-Federal entity fiscal years beginning on or after the effective date. For UA, this means FY16 (July 1, 2015 to June 30, 2016)

5. 2 CFR 200 – Basic Layout 6 Subparts A-F
Subpart A, 200.XX – Acronyms & Definitions
Subpart B, 200.1XX – General
Subpart C, 200.2XX – Pre Award
Subpart D, 200.3XX – Post Award
Subpart D, 200.4XX – Cost Principles
11 Appendices I through XI, e.g.
Appendix II: Contract provisions
Appendix III: IDC calculation

6. Use of “should” and “must”
Significant Changes
Definitions
One set of definitions applicable to all requirements and all types of grantees
Use of “should” and “must”
Should = best practices or recommended approach
Must = required
Emphasis on Internal Controls
Mentioned 103 times

7. §200.68: Modified Total Direct Costs (MTDC)
Significant Changes
§200.68: Modified Total Direct Costs (MTDC)
Participant support costs are excluded from the MTDC, all sponsors not just NSF
This means no indirect costs will be allowed for participant support costs
§ : Conflict of Interest
Require Federal awarding agencies to establish a conflict of interest policy. Non-Federal entity must disclose in writing any potential conflict of interest to the Federal awarding agency or pass-through entity
§ : Fixed Amount Awards
Use of fixed amount awards to minimize compliance requirements in favor of requirements to meet performance milestones

8. §200.207: Specific Conditions
Significant Changes
§ : Specific Conditions
Require Federal awarding agencies to evaluate the merit and risks associated with a potential Federal award and to impose specific conditions necessary to mitigate potential risks of waste, fraud, and abuse, before the money is spent.
§ : Internal Controls
Requires recipients to have strong internal controls in compliance with “Standards for Internal Control in the Federal Government” and “Internal Control Integrated Framework” issued by COSO (Committee of Sponsoring Organizations of the Treadway Commission)
§ : Cost Share
Voluntary committed costs sharing may never be considered during the proposal merit review.

9. §200.320: Methods of Procurement
Significant Changes
§ : Methods of Procurement
Micro-purchaces: less than 3K, no rate quotations
Small Purchases: 3K-150K, rate quotations required
UA issues
UA P-Card threshold is 5K (common threshold among many Universities)
P-Card purchases will require the attachment of three rate quotations in order to be allowed on federal accts
Cost transfers will not be allowed if three quotes were not included with the original purchase
Many institutions are considering reducing P-Card threshold to 3K to minimize risk

10. §200.320: Methods of Procurement continued
Significant Changes
§ : Methods of Procurement continued
Applies to next full fiscal after 12/26/2014 (for UA 7/1/2015)
OMB has provided a one year grace period to implement this new requirement (for UA 7/1/2016)
Must document you will continue to use OMB A-110 in order to take advantage of the one year grace period

11. §200.331: Subrecipient Monitoring
Significant Changes
§ : Subrecipient Monitoring
Requires the data elements provided to subrecipient.
Provides detailed monitoring procedures such as reviewing financial and programmatic reports, performing on‐site reviews, and engaging external auditor to perform agreed‐upon‐procedures for subrecipient monitoring
§ : Fixed Amount Subawards
Written approval required for fixed amount subawards up to $150K
Fixed amount subawards not allowed when cost share is required

12. Significant Changes
§ : Closeout
Federal agencies have begun strict enforcement of the 90-day closeout requirement since the requirement existed prior to UG
ability to draw funds via letter of credit is removed on day 91
late invoices are rejected
UG allows for unilateral closeout (sponsor can closeout award without agreement from recipient)
sponsors are using the unilateral closeout by closing the award at the payment level on day 90

13. Significant Changes
§ : Closeout continued
Agencies are promising to use every compliance and enforcement tool at its disposal including debarment of Principal Investigators (Pis) who are delinquent with technical reports
NSF and NIH are considering a 120-day closeout but nothing is official (more to come)

14. §200.407: Prior Written Approval
Significant Changes
§ : Prior Written Approval
provides a list of the UG paragraphs that may contain prior approval requirements
§ : Administrative and clerical salaries can be treated as direct costs only when all conditions are met:
Services are integral to a project
Individuals can be specifically identified with the project
Costs are explicitly budgeted or have prior written approval
Costs are not also recovered as indirect costs

15. §200.415: Required Certification
Significant Changes
§ : Required Certification
the annual and final fiscal reports or vouchers requesting payment under the agreements must include a certification, signed by an official who is authorized to legally bind the non-Federal entity, which reads as follows:

16. §200.415: Required Certification
Significant Changes
§ : Required Certification
“By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (U.S. Code Title 18, Section 1001 and Title 31, Sections and ).”

17. §200.430 Compensation –personal services
Significant Changes
§ Compensation –personal services
Removes examples, OMB is advertising that effort reporting is no longer required, but the requirements have not really changed and switched emphasis to internal controls:
(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides
reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE’s
definition of IBS); (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated
basis, but may include the use of subsidiary records as defined in the non …

18. §200.431: Compensation - fringe benefits
Significant Changes
§ : Compensation - fringe benefits
The costs of unused leave upon termination may not be directly charged to Federal awards
The costs may be charged via fringe rates
Timing issues UA
UA approved fringe rates 7/1/2014-6/30/2015
New rates with term pay would take effect 7/1/2015
UG applies as of 12/26/2014
Institutions are split between cash and accural, this section is an issue only if you are currently on cash

19. §200.438: Entertainment Costs
Significant Changes
§ : Entertainment Costs
Entertainment costs that have a programmatic purpose and are approved in budget or with a prior written approval are allowable
§ : Computing devices
Computing devices costing less than $5,000 are treated as supplies. As long as the devices are essential and allocable, the costs are allowed as direct costs even when the devices are not solely dedicated to the performance of an award.
§ : Publication and printing costs
Costs can be charged prior to closeout if costs are not incurred during the period of performance
Need more clarification

20. Questions Questions UG and FAQs can be found at: