Uniform Guidance
On December 26, 2013, the Office of Management and Budget (OMB) issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements (Uniform Guidance) for federal awards in the Federal Register. The Uniform Guidance streamlines and supersedes guidance that was previously contained in eight different OMB Circulars. Included in the new guidance are definitions, uniform administrative requirements (both pre- and post-award), cost principles, and audit requirements. From the university perspective, the Uniform Guidance will supersede OMB Circulars A-110, A-21, and A-133.
For an overview on Concepts That Are Changing click here.
Jump To:
- Summary of Uniform Guidance: Concepts that are Changing
- September 5, 2014 Announcement to the Research Community on The Uniform Guidance
- FAQs for Proposing and Direct Charging Administrative and Clerical Salaries
- FAQs for Direct Charging Administrative Supplies
- ABC Presentation September 23, 2014
- What is Stanford Doing to Implement the Uniform Guidance?
Summary of Uniform Guidance: Concepts that are Changing
September 5, 2014 Announcement to the Research Community on The Uniform Guidance
Announcement to Stanford Research Community
On December 26, 2013, the Office of Management and Budget (OMB) issued Uniform Guidance that will replace the administrative, accounting, audit rules and principles currently promulgated in OMB Circulars A-21, A-110, and A-133. The Uniform Guidance is effective for federally sponsored agreements and new funding increments awarded on or after December 26, 2014. OMB Circulars A-21 and A-110 are effective for federally sponsored agreements awarded before December 26, 2014.
Faculty will receive a separate communication regarding these policy changes next week.
Effective Immediately
Proposals submitted for federally sponsored projects expected to be awarded on or after December 26, 2014 will reflect the changes in the following cost categories:
- Charging Administrative and Clerical Salaries to Sponsored Projects
- Charging Computing Devices to Sponsored Projects
These changes should be reflected in proposal submissions as soon as practical.
1. Charging Administrative and Clerical Salaries to Sponsored Projects
Stanford’s policy reflects section 200.413 of the Uniform Guidance, which establishes the principle that the salaries of administrative and clerical staff should normally be treated as Facilities and Administrative (F&A) or indirect costs. It also reflects the circumstances where it is appropriate to charge administrative expenses directly to federally sponsored projects. Uniform Guidance eliminates the “major project” standard from A-21 for the direct charging of administrative and clerical salaries.
Direct charging of these costs to federally sponsored projects is appropriate only if ALL of the following conditions are met:
- Administrative or clerical services are integral to a project or activity
- The requirement that the cost is “integral” means the services are essential, vital, or fundamental to the 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
- A budget justification must be included in the proposal
- The costs are not also recovered as indirect costs
Federal awards received before December 26, 2014 must continue to follow the requirements in OMB A-21 and Stanford’s policy on Charging for Administrative and Technical Expenses (RPH 15.4).
Any other administrative costs that are required to perform the technical scope of work may be directly charged as long they provide technical benefit to the sponsored project.
Non-federally Sponsored Projects: Direct charging of administrative or clerical salaries to a non-federally sponsored project is appropriate if the services benefit the sponsored project. Some non-federal sponsors may have specific requirements for direct charging of administrative costs. Such requirements need to be addressed in proposals.
2. Charging Computing Devices to Sponsored Projects
Stanford’s policy reflects section 200.20 of the Uniform Guidance that defines Computing Devices and section 200.453 (c) that establishes that such costs are supplies and may be charged directly to federally sponsored projects as described below.
Computing Devices are machines that cost less than $5,0001 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.
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Charging computing devices as direct costs is allowable for devices that are essential and allocable (provide benefit), but are not solely dedicated, to the performance of a federal award.
- Such devices are also allowable if solely dedicated to the performance of a federal award
- Federal sponsors may impose requirements for these costs to be included in the proposal budget and may require a budget justification. Until the federal agencies release specific information, budget justifications may be used at the discretion of the principal investigator. Requirements may be forthcoming from each sponsoring agency in fall 2014 or winter 2015.
- Inventory tags may be affixed to computing devices at the discretion of the department; inventory tagging facilitates accountability, availability for reuse, and appropriate disposal.
Non-federally Sponsored Projects: Direct charging of computing devices to a non-federally sponsored project is appropriate if the computing device benefits the sponsored project. Some non-federal sponsors may have specific requirements for direct charging of computing devices. Such requirements need to be addressed in proposals.
Stanford’s policy (RPH 15.4) on charging other technical expenses remains unchanged by the Uniform Guidance.
1There is no change in policy regarding treatment of items over $5,000. If the acquisition cost of a computer is greater than $5,000 (and has useful life of more than 1 year), it should be categorized as capital equipment. See the Property Management Manual for more information regarding capital equipment.
Information about the implementation of the Uniform Guidance at Stanford including a copy of this policy announcement and related FAQs, and other important information can be found on the DoResearch website.
For questions about these policies, please contact your institutional representative in the Office of Sponsored Research, the Research Management Group, Engineering Research Administration, or me at sbible@stanford.edu or 723.9050.
FAQs for Proposing and Direct Charging Administrative and Clerical Salaries
- How does the integral definition change our current policy?
A project no longer needs to be identified as “major;” however, the administrative salary expense needs to be integral or essential to the project in order to be direct charged. It must also be included in the proposal budget and justification. Most of the other requirements for direct charging salary are the same as with major projects.
- What should be included in a budget justification for charging administrative/clerical salaries?
A description of administrator’s salary that is being proposed and what makes it integral to the sponsored project. This should include:
- a description of the administrator’s role
- how the administrator’s effort relates to and benefits the project
- the level of effort expressed as a percentage FTE or person months per sponsor instructions
- the time period(s) in which the person will be working
- any other information that will aid the sponsor in evaluating and funding the proposed salary.
NOTE: Although NIH modular grants or similar grant instruments do not require line-item justifications, the personnel, including administrative salaries, do need to be described in a modular budget’s justification.
When you prepare your PDRF in SeRA, there will be a question about whether the administrator’s salary is “integral” to the project. A “yes” response will trigger a flag is SeRA to indicate that the administrator’s salary is “integral.”
- Does the “integral” criteria apply to non-federal sponsored projects?
Most non-federal sponsors do not require the administrative activity to be integral. However, some non-federal sponsors may include such a requirement or the sponsor may incorporate OMB Uniform Guidance requirements. Check the terms and conditions of the award to determine if your non-federal projects have adopted the Uniform Guidance or the “integral” requirement.
- Is there a minimum threshold for charging administrative and clerical salaries in order for it to be considered integral?
No, but you must consider that there is a continuum in terms of the amount of effort devoted and charged to the sponsored project. The lower the percentage effort proposed, the more difficult it may be to document and justify the integral nature of the activity.
- Is an administrator’s review of quarterly expenditure statements or annual payroll distribution considered integral?
This activity would not be considered integral for most sponsored projects. This activity may be considered integral for program project grants, projects that involve multiple faculty and/or multiple institutions, or projects with significant administrative complexity.
- My project is funded by a non-federal sponsor. What administrative activities can I charge directly to my project?
You may charge any administrative activities and the related costs that provide benefit to the sponsored project and are within the terms and conditions of the sponsored agreement.
- What are some types of proposals at Stanford that might have administrative salary charges that would be considered integral?
Some examples include:
- Any grant mechanism that provides for an administrative core, such as NSF Engineering Research Centers, NIH program project grants, NIH Center grants such as the Spectrum Stanford Center for Clinical and Translational Research and Education, etc.
- Projects that require making travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
- Projects that require monitoring and management of multiple subawards and/or foreign subawards
- I budgeted for an administrator’s salary and the sponsor lined it out. Do I have to cost share the administrator’s salary if they will still perform the work?
No.
- If my project was classified as “major,” and additional funding is received on or after December 26, 2014, what should I do?
It will need to follow the definition of “integral” under the Uniform Guidance. If it previously met the major project criteria, it will most likely meet the “integral” requirement. (See Note re: PDRF flag under Q. 2.)
FAQs for Direct Charging Administrative Supplies
Charging administrative costs for technical purposes has not changed and does not require the project to be “major” nor the expenditure to be “integral.” The allocable (benefiting), allowable and reasonable criteria are the same.
- How will a reviewer know that the administrative items I’m charging to the project are allocable?
Since the benchmark is no longer project based (i.e., Major Project) but transaction based (i.e., allocable to the project) it is important to articulate its need and benefit to the project in the transaction, itself (e.g. purchase order, Pcard transaction, reimbursement, etc.) Of course, this is true for all transactions, but especially so for administrative-appearing items.
ABC Presentation September 23, 2014
What is Stanford Doing to Implement the Uniform Guidance?
In preparation for the December 26th, 2014 implementation date, we have created a subcommittee to review and catalog changes that may be required due to the new Uniform Guidance.
The group is responsible for determining the impact of the new regulations to existing policy and process, creating new training materials and revising policies where needed, and ensuring broad and effective communication strategies.
Members of the Subcommittee on Uniform Guidance include:
Sara Bible, DoR - Chair Russell Brewer, OSR
Patti McCabe, DoR Ken Merritt, DoR
Ken Schulz, RFCS Kathleen Thompson, RMG
Rocco Cappalla, Controller's Office
Rick Moyer Audit, Compliance and Privacy Sonal Shah Audit, Compliance and Privacy
