Uniform Guidance Requirements
The following identifies key elements of the Federal Uniform Guidance (UG) applicable to federal awards The items listed below represent a change from the previous Federal Regulations contained in OMB Circulars A-21 and A-110. Not all changes are noted, only those that may significantly affect the Ohio University research community.
Pre/Post-Award questions can be directed to the Office of Research and Sponsored Programs at firstname.lastname@example.org. Financial questions can be directed to email@example.com, or see your LEO award letter for your Grants Accounting contact information. Also, see below for additional federal contract requirements.
LEO: Electronic Awards Administration System: Award specific requirements and documents
Indirect Cost Rate Agreement (Facilities and Administrative Cost Rates) negotiated with the Department of Health and Human Services on January 16, 2019. These rates remain in effect until June 30, 2023.
|Category||Details||Link to Regulation|
All organizational levels of the institution (OHIO) must have internal controls to ensure compliance:
|Participant Costs (Trainees/Students)||Participant support costs are exempt from indirect costs and require agency approval to re-budget for other purposes. This is documented in the Ohio University Participant Costs guidance.||200.1|
|Application of Guidance||Two sets of regulations will be in place and will depend on the issuance and effective date of the federal award. New awards and additional incremental funding (funding increments) to existing awards will fall under the new guidance. Existing awards not receiving incremental funding will continue to be governed by the terms and conditions under which they were awarded.||200.110|
|Information Contained in a Federal Award||Some awards contain more prescriptive requirements for the content and timing of technical/scientific progress and financial reports. It is important to read your award terms and conditions.||200.211|
|Cost Sharing||Voluntary cost share is discouraged. When cost share is required by the sponsor and committed to by OHIO it becomes a binding commitment. Agency approval is required to claim the indirect costs related to direct costs, or waived indirect costs, as part of a cost share commitment. The cost share process is documented in the Accounting for Cost Share guidance.||200.306|
|Program Income||For all awards generating revenue (Program Income), this income is to be used for costs in support of the project unless the agency specifies otherwise. Agencies may require accountability for income earned after the award ends.||200.307|
The Micro-Purchase Threshold (MPT), required by Uniform Guidance was implemented on July 1, 2018 which included M-18-18 OMB Statutory changes. In an effort to reduce the impact and keep administrative burden for principal investigators and researchers as low as possible, the University requested and received approval on November 13, 2018, from the University’s federal oversight agency, to adjust the MPT limit to $50,000 (from the current level of $10,000). As a result of this change, the requirement to obtain three (3) quotes for expenditures against federal awards, has been eliminated.
This change aligns both the University competitive bidding threshold (as required under the Ohio Revised Code section 125.05 and University policy 55.007 - Competitive Bidding) and the MPT at $50,000. All purchases that are $50,000 or more, against any source of funds (including federal), must be competitively bid through Purchasing.
This is documented in the Ohio University Federal Procurement guidelines.
|Subrecipient Monitoring||Requires assessment of risk, as well as the monitoring and management of subrecipients has been clarified and redefined. Includes Finance and Administration rates. Subrecipients are entitled to receive their federally negotiated indirect cost rate or, if they do not have one, a 10% rate, unless the federal award restricts the indirect cost rate.||200.331|
|Records Retention||Electronic records are preferred to paper records. When paper documents are substituted for electronic documents they are subject to periodic quality control reviews.||200.334|
|Closeouts||Final progress, financial and other reports are due no later than 90 calendar days after the end date of the period of performance.||200.344|
|Prior Approvals||Prior written approval from the agency may be required or advisable for certain special/unusual costs.||200.407|
|Administrative and Clerical Staff Costs||Administrative and Clerical salaries in general, should not be direct charged, but are allowable if the services meet the “integral” definition, are easily identifiable, and are explicit in the budget. These may be allowable as direct costs if the four requirements are met. 1. Administrative or clerical services are integral to a project or activity; 2. Individuals involved can be specifically identified with the project or activity; 3. Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and 4. The costs are not also recovered as indirect costs.||200.413 (c)|
|Dependent Care Costs during Conferences||For conferences, the costs of identifying, but not providing, locally available dependent-care resources are allowable.||200.432|
|Exchange Rate Fluctuations||Cost increases for fluctuations in exchange rates are allowable, subject to the availability of funding and prior approval by the agency.||200.440|
|Computing Devices||If a computing device’s cost is less than $5,000 and it is essential and allocable to the performance of the project, it may be direct charged. The device must be 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.||200.453|
|Pre-Award Costs||Costs incurred prior to the effective date of the award must be necessary for efficient and timely performance of the award. All pre-award costs may require prior approval of the agency.||200.458|
|Publication and Printing Costs||Costs of publication or printing of research results may be charged to the project, even after the end of the award period. This must be recorded as an expense within 60 days of the end date of the award (per OHIO requirements) or the final report deadline for the award whichever is earlier.||200.461 (3)|
|Short-Term Travel Visa Costs||Short term visa costs are allowable under certain conditions, but long term (immigration) visa costs are unallowable.||200.463 (d)|
|Travel||You must document how each individual’s travel is necessary to the federal award.||200.474|
Federal Contract Requirements