Uniform Guidance

On December 26, 2013, the Office of Management and Budget (OMB) issued the “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards,” known as Uniform Guidance.  Uniform Guidance consolidates eight existing OMB Circulars that provide the overarching framework for managing federal research funding. The new guidance, which affects all federal grants and contracts, took effect on December 26, 2014.

Under the leadership of Michelle A. Lewis, Director of Research Administration, Weill Cornell Medicine set up a Medical College-wide review committee to coordinate implementation of the Uniform Guidance. The following information highlights key changes most relevant to Weill Cornell Medicine Faculty and their administrators. Additional questions can be directed to uniformguidance@med.cornell.edu.

Key Components for Weill Cornell Medicine Faculty

Administrative and Clerical Salaries

Generally, administrative and clerical salaries should be treated as facilities and administrative costs on federally sponsored projects; however, when certain criteria are met, they may be allowed as a direct cost. The Uniform Guidance eliminates the major project or activity exceptions (i.e. Programs Projects and Cooperative Agreements) for the direct charging of administrative and clerical salaries and has replaced it with the following criteria, all of which must be met:

  • Administrative or clerical services are integral to a project or activity
  • Individuals involved can be specifically identified with the project or activity
  • Such costs are explicitly included in the budget or have the prior written approval of the federal awarding agency (for the National Institutes of Health (NIH), prior written approval is not required)
  • If all of these requirements are met, then administrative/clerical expenses may be included in the proposal. Costs must be detailed in the project budget justification, which must also include confirmation that the costs are not recovered as indirect costs. Although the NIH has waived its right to pre-approve these expenses, OSRA will require a justification for auditing purposes. It is WCM’s policy that, in order to mitigate the risk of cost disallowance at any phase of the project (active, close-out or post audit), any attempt to direct charge administrative/clerical salaries must meet all criteria outlined in the uniform Guidance, including prior written approval.

    Like all costs charged to federal grants, administrative salaries must be reasonable, allocable to the project, consistently applied and conform to the grant award terms and conditions. The following language is recommended for use in the budget justification:

Award Closeout

National Institutes of Health (NIH) grant recipients are now required to submit a final Federal Financial Report (FFR), Final Progress Report and Final Invention Statement no later than 120 days after the end date of the award period of performance. In order to comply with NIH cash reimbursement practices and remain compliant with closeout policy requirements, departments are expected to complete all account transactions 75 days following the grant end date to allow sufficient time for Finance to review and submit the FFR.

The National Science Foundation (NSF) does not require grantees to submit FFRs for each award. Instead NSF grant recipients must liquidate all obligations incurred under their awards no later than 90 days after the award end date, however it is anticipated NSF will revise to the new 120 requirement.

For projects that include subawards, the sub-recipient must submit all final billings well in advance of the 90 or 120 day period. Current practice requires all sub-recipient documents no later than 60 days after the end date of the award period of performance.

Computing Devices

Computing devises are machines that cost less than $5,000 and are used 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.

Charging computing devices as direct costs is allowable for devices that are essential to performing the work and allocable (provide benefit), but are not solely dedicated to the performance of the federal award. All such devices should be identified and justified in the proposal budget justification. The project must not have reasonable access to other devices or equipment that can achieve the same purpose; devices may not be purchased for reasons of convenience or preference.

Similar devises that cost $5,000 or more must be identified and treated as equipment.

Conference & Travel Policies

Uniform Guidance provides the following, which must be applied consistently across the Institution.*

  1. As the host or sponsor of a conference, it is allowable to charge the costs of identifying, but not providing, locally available child-care resources. These costs must not be further restricted by the Federal award terms and conditions and be managed so as to minimize the cost to the federal award.
  2. Allows the cost of temporary dependent care costs required to enable personnel to travel in support of the project’s aims.

*In order to charge these expenses to federal grants, institutions must have a standard policy of paying such expenses on all fund sources. Until WCM implements such a policy, these expenses will not be charged to federal grants. Please follow all applicable Weill Cornell Medicine (WCM) guidelines and sponsor terms and conditions until further notice.

Cost Sharing

Uniform Guidance confirms that the federal government does not expect voluntary committed cost sharing in proposals. It cannot be used as a factor during the merit review of applications or proposals unless it is both in accordance with federal awarding agency regulations and specified in the notice of funding opportunity.

Any voluntary cost sharing identified in a proposal becomes mandatory should the proposal be funded.

Publication Costs

Uniform Guidance allows publication costs to be charged to the award after the performance period has ended, however these costs must be charged to the project prior to the close out period end date. In order to meet all reporting obligations, Weill Cornell Medicine requires that all publications costs be posted in SAP within 90 days of the period of performance end date.

Visa Costs

Uniform Guidance clarifies when visa costs are allowable as a direct cost on federal awards. Short-term, travel visa costs (as opposed to longer-term, immigration visas) are generally allowable expenses that may be proposed as a direct cost. Since short-term visas are issued for a specific period and purpose, they can be clearly identified as directly connected to work performed on a federal award. For these costs to be directly charged to an award, they must be critical and necessary for the conduct of the project and be allowable under the applicable cost principles.

Basic visa application and required fees, such as anti-fraud fees, are allowable direct costs provided they meet this definition. As this is classified as a recruiting cost, only the initial visa cost is allowable.

 

FULL UNIFORM GUIDANCE - 2 CFR 200

Preamble - Major Policy Reforms
Subpart A (200.0 - 200.99) – Acronyms and Definitions
Subpart B (200.100 - 200.113) - General Provisions Subpart C (200.200 - 200.211) - Pre Award Requirements
Subpart D (200.300 - 200.345) - Post Award Requirements
Subpart E (200.400 - 200.475) - Cost Principles
Subpart F (200.500 - 200.521) - Audit Requirements (includes Appendices I-XI) -Subpart F will apply to audits of fiscal years beginning on or after December 26, 2014

In addition, the Uniform Guidance Table of Contents is a useful resource.