1. 1 Recent Changes Published in Part 200 Uniform Guidance -- Cost Principles Steve Bradley, Director

2. 2 Agenda –New Structure (“Roadmap”) Highlighting relevant F&A and Cost Principle sections –Costing Principles Including eliminations of prior A-21 sections MAXIMUS Impact Assessment –Resources

3. 3 Structure (cont.) –Subpart E – Cost Principles (A-21, A-87, A-122) General Provisions§ 200.400 to 401 Basic Considerations (Cost Allowability, Applicable credits) § 200.402 to 411 Direct and F&A Costs (including required Certifications) § 200.412 to 415 State, Local & Indian Govt § 200.416 to 417 Special Considerations for Institutions of Higher Education § 200.418 to 419 General Provisions for Selected Items of Cost (Prior A-21, section J) § 200.420 to 200.475

4. 4 Structure (cont.) –Subpart F – Audit Requirements (A-133) –Appendices (combination of all 8 Circulars) I – Notices of Funding II – Contract Provisions III -- F&A for Educational Institutions (A-21) IV – Indirect for Non-Profits (A-122) V – State/Local Cost Allocation Plans (A-87) VI – Public Assistance (A-87) VII – State/Local Indirect Cost Plans (A-87) VIII – Non-Profit Exemption from Cost Principles (A-21) IX – Hospitals (TBD) X – Audit Data Collection (A-133) XI – Single Audit Compliance Supplement (A-133)

5. 5 OMB Changes – Combine Circulars Consolidate A-87, A-21 and A-122 Cost Principles Create a common accounting standards for all grant recipients IMPACT --Probably add more confusion than clarity --Universities are much different than Non- profits and State/Local Govt’s --Document littered with “exceptions” (e.g., A-21 26% Admin cap )

6. 6 OMB Changes – Flat Rate For F&A costs, use a flat rate instead of current negotiated rate system – NOT in new guidance IMPACT GREAT! Flat / “tiered” rate idea was not well received and has been dropped

7. 7 OMB Changes – UCA (App. III B.4.c) Maximum 1.3 Utility Cost Adjustment with “Utilities” allocations based on “Effective square footage” ESF is actual SF times “Relative Energy Utilization Index (REUI) REUI is currently 2X OMB will adjust factor “no more often than annually nor less often than every 5 years” Allows metering at a Sub-Building level???? IMPACT GREAT (for some)! Increase burden (for others)! Perhaps a Double-Edged Sword? Schools will now have to develop data for their Utilities pools “Separate Proposal”

8. 8 OMB Changes – Eliminate Required Study Eliminate requirement for institutions to conduct studies for cost reasonableness for Large Research Facilities prior A-21, F2 IMPACT --GREAT! --Reduce administrative burden

9. 9 OMB Changes – Eliminate Mandated F&A Usage Eliminate requirement that certain institutions must use F&A recoveries associated with depreciation to acquire or renovate research buildings or equipment prior A-21, J14h Currently applies to 99 schools IMPACT --GREAT! --Reduce administrative burden

10. 10 OMB Changes – Eliminate Required Analysis Eliminate requirement that schools perform a Lease Purchase Analysis to justify External Bond Interest prior A-21, J26 now Subpart E, 200.449 IMPACT --GREAT! --Reduce administrative burden --But, Retained “25% Equity Contribution” rule

11. 11 OMB Changes – DS-2 (Subpart E, 200.419) Disclosure Statements (DS- 2) & Compliance under the Cost Accounting Standards Board (CASB), retained (prior A-21, C14) Threshold raised from $25M to $50M Added: University proposed change must be submitted to DCA/ONR 6 months in advance IMPACT --Reduce administrative burden? Change in effect next FY unless hear from DCA/ONR

12. 12 OMB Changes – 10% Rate for First-timers Addition of 10% de- minimus indirect cost rate (modified total direct cost basis) for entities that do not currently have a negotiated rate Subpart E, 200.414 IMPACT GREAT! --May reduce the need for university staff to review indirect proposals from these type sub awardees / subcontractors

13. 13 OMB Changes – Cost Sharing Affirm that Voluntary Committed Cost Sharing is NOT expected & is NOT to be used as a factor in review of applications Subpart D, 200.306 Only mandatory cost sharing and cost sharing specifically committed in the project budget must be included in the organized research base IMPACT GREAT! --Probably reduce administrative burden and/or Organized Research “base” --VUCS clarification still in effect

14. 14 OMB Changes – Direct Charging of Admin. Salaries of administrative staff may be direct charged to federal grants where ALL of the following are met: Services are integral to the project Individuals can be specifically identified to the project Explicitly included in the budget or have prior written approval AND, are not recovered as indirect costs Subchapter E, 200.413 IMPACT DOUBLE-EDGED SWORD! --May reduce confusion --But may increase the Organized Research MTDC base and, in turn, lower proposed rates --As offset, F&A rates would be applied to these new direct costs, increasing F&A Dollar Recoveries

15. 15 OMB Changes – Rate for All Agencies Require Federal agencies to accept negotiated indirect (F&A) cost rates, unless an exception is required by statute or regulation; and, Federal agency must notify OMB of any approved deviations Subpart E, 200.414 IMPACT Regrettably, not much change Except, OMB will now have central repository of these For example, USDA, 8% Training grants, etc., will probably stay at reduced F&A rates

16. 16 OMB Changes – Effort Certification Remove the “Examples of Acceptable Methods for Effort Certification for Payroll Distribution” Emphasis on “Internal Controls” and “Performance” prior A-21, section J10 Subpart E, 200.430 IMPACT Reduces Effort Certification burden Allows “flexibility in how universities can meet standards” “Final guidance does not require current PAR’s/similar documentation” Also, FDP doing their own “Project Certification” Demo, including reviews by OIG’s

17. 17 OMB Changes – Rate Extension All Non-Federal entities may apply for a one-time extension of current F&A rates for up to four years, subject to cognizant agency approval Subpart E, 200.414 IMPACT May be appropriate for some universities For others, may reduce F&A dollar Recoveries (e.g., if major new research buildings, if now eligible for UCA, or substantial decrease in base re: end of ARRA grants)

18. 18 OMB Changes – Computing Devices Addition of new language which allows “Computing devices” and associated support costs to be treated as allowable and allocable direct costs Subpart E, 200.453 IMPACT DOUBLE-EDGED SWORD! May reduce confusion But may increase the Organized Research MTDC base and, in turn, lower proposed rates As offset, F&A rates would be applied to these new direct costs, increasing F&A Dollar Recoveries

19. 19 OMB Changes – MTDC (App. III C.2) App. III C.2. references section 200.68 where participant support costs, defined in 200.75, are listed as an exclusion to MTDC Other items may only be excluded when necessary to avoid a serious inequity in distribution of indirect costs, and with the approval of the cognizant agency IMPACT -- Perhaps increase burden to identify new exclusion -- Possibly deter agencies adding unfair base exclusions (e.g. genomic arrays)

20. 20 OMB Changes – Library Expenses (App. III B.8) The professional employee category can include post- doctorate fellows and graduate students The other users category can be based on a reasonable factor as determined by institutional records to account for all other users of library facilities IMPACT --GREAT! --Support standard practice allocation to postdocs and grad students --Reduce administrative burden

21. 21 OMB Changes – Dual Role of Students Kept language stating “ … the dual role of students as both trainees and employees contributing to the completion of Federal awards for research must be recognized in the application of these principles.” Subpart E, 200.400(f) IMPACT --GREAT! --May have reduced F&A rates if omitted

22. 22 Unresolved Issues When will revised DCA Best Practices Manual be published? UCA for FY14 base year F&A rate proposals? Definition of “monitored research laboratory space” re: UCA Format for “separate calculation proposal” for UCA Does “one time” extension mean once in the life of the rate or once in the life of the institution Send questions to COFAR cofar@omb.eop.govcofar@omb.eop.gov

23. 23 Resources http:// www.maximus.com/ our-services/education/higher- education/omb-uniform-guidance Federal Register article: Web | PDF 2 CFR Part 200: eCFR - Code of Federal Regulations The OMB website includes many helpful links: OMB Policy Statements: Uniform Grant Guidance Crosswalk from Existing Guidance to Final Guidance Crosswalk from Final Guidance to Existing Guidance Cost Principles Comparison Chart Audit Requirements Comparison Chart Definitions Comparison Chart Administrative Requirements Comparison Chart COFAR

24. 24 Contact Us Email: highereducationinfo@maximus.comhighereducationinfo@maximus.com Telephone: 800-709-2747 Website: http://HigherEducation.MAXIMUS.comhttp://HigherEducation.MAXIMUS.com Facebook: MaximusHEP Twitter: #MaximusHigherEd