OMB Uniform Guidance at UMass

On December 26, 2013 the Office of Management and Budget (OMB) released its final rule of “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (2 CFR Chapters I, II, Part 200, et al), and continues to provide interim updates.

The Uniform Guidance consolidates and replaces OMB Circulars A-110 (Administrative requirements), A-21 (Cost principles), and A-133 (Audit requirements). The Uniform Guidance (UG) applies to all new federal awards issued on or after December 26, 2014. Modifications adding new funding to awards issued prior to that date may also include a clause updating the terms of the award to fall under UG.

Important Changes in the UG

This page describes specific differences between the Uniform Guidance and its predecessors, Circulars A21, A110, and A133.

Select any of the links below to find out more about changes resulting from the Uniform Guidance.

Timeline

§  December 26, 2013– OMB issued the final rule of the Uniform Guidance (UG).

§  December 19, 2014 Joint Interim final rule published:  Includes OMB updates to UG and Federal agency-specific plans for implementing UG.

§  December 26, 2014– UG went into effect. 

§  July 1, 2015– Uniform Guidance audit requirements are applicable to awards.

§  July 1, 2016– Uniform Guidance procurement requirements are applicable to awards.

Agency Updates

The National Science Foundation (NSF)

National Institutes of Health (NIH)

  • Interim General Grant Conditions serve as the applicable terms and conditions for recipients of NIH awards and are aligned with the HHS regulations implementing the Uniform Guidance (UG).  The conditions are effective for Notices of Award (NoA) issued on or after December 26, 2014 that obligate new or supplemental funds.
  • Notices of Award (NoA) issued on or after December 26, 2014 that do not involve obligation of new or supplemental funds remain subject to 45 CFR Part 74.
  • See also NIH's 45 CFR Part 75 related FAQs.

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Uniform Guidance Working Group at UMass

Jennifer Donais – Assistant Vice Chancellor for Research
Robert Liebowitz – Controller
Ian Raphael – Director of Research Business Manager Liaisons
Carol Sprague –Director, Grant and Contract Administration
Research Administration Advisory Board Members

Additional Resources

Office of Management and Budget

Other Federal Resources

Council on Governmental Relations (COGR)

Videos from NCURA

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Only Cost Share When it is Required by the Solicitation

Cost Sharing or Matching: (As defined by 200.29 (link is external)) is the portion of project costs not paid by Federal funds unless otherwise authorized by Federal statute.  All cost sharing must be tracked and maintained in a separate account.

Voluntary Cost Sharing: (As defined by 200.99 (link is external)) is specifically pledged on a voluntary basis in the proposal’s budget or the Federal award on the part of the non-Federal entity and that becomes a binding requirement of the Federal award.

Section 200.306 (link is external) specifies that cost sharing or matching should only be solicited for research proposals when required by regulation and transparent in the notice of funding opportunity.  Voluntary committed cost sharing is not expected under Federal research proposals and is not to be used as a factor in the review of applications or proposals unless it is specifically stated as such in the announcement. Only mandatory cost sharing or cost sharing committed in the budget must be included in the research base for computing F&A cost rate.

Shared costs, matching funds, and contributions must meet certain criteria to be accepted as cost sharing.  In particular, salary costs above a Federal awarding agency’s cap are not mandatory cost-share or match.  For more information on the criteria for cost-sharing allowability, go to Section 200.306 (link is external).

For more information on cost sharing transparency in funding opportunities, go to Appendix I to Part 200 – Full Text of Notice of Funding Opportunity; E. Application Review Information, 1. Criteria – Required (link is external).

Impact at the University of Massachusetts:

  • The University’s Cost Sharing Policy is consistent with these requirements.
  • Research proposals for federal grants must only include cost sharing when it is required by the solicitation.

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Definition of Allocable Expanded from “Solely” to “Specifically”

Section 200.405(link is external) language in the guidance changed from “incurred solely for the Federal award” to “incurred specifically for the Federal award”.  Federal funds cannot be used to overcome deficiencies or reasons other than those specified at the time of the award.  If an incurred cost benefits two or more projects, the cost should be allocated proportionately; costs for equipment purchased under an award are allocable regardless of the use of the equipment when it is no longer needed.

Impact at the University of Massachusetts:

  • PI’s must properly evaluate the circumstances where proportional costs are to be applied to these types of cost categories and write a proper budget justification backing up the evaluation.  OGCA will carefully analyze fair and appropriate direct cost allocation methodologies.
  • This section also continues and reinforces the cost principles of the old A-21 in that costs charged to sponsored projects must meet the following criteria:
    • Allowable – The cost is permissible according to federal regulations, sponsor policy and award terms and conditions.
    • Allocable – Must provide a “benefit” to the project.
    • Reasonable – The “prudent person” test – would a prudent person purchase the item at this cost? The cost is necessary for the performance of the activity.
    • Consistent – The cost is consistent with established University policies and procedures.

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Items Requiring Pre-Approval

Section 200.407. Specifies that the institution may want to seek prior written approval to avoid subsequent disallowance or dispute based on unreasonableness or nonallocability.  Many items require pre-approval.  For the full list, go to Code of Federal Regulations - Title 2 Section 200.407. (link is external)

Changes have been made regarding the following items requiring pre-approval:

  • Revisions to the budget or program plan.  See also Making Changes.
  • Overloads (Section 200.430)
  • Cost increases for fluctuations in exchange rates (Section 200.440).  See also Foreign Activities.
  • Participant support costs (Section 200.456).  See also Participant Costs.

Impact at the University of Massachusetts:

  • Any costs that you anticipate incurring during the performance of your research project should be included in your proposal budget and budget justification.
  • Post-award changes to costs requiring pre-approval must be requested in writing before the change is made.  Contact your OGCA award administrator for more information.

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Conflict of Interest Disclosures to be Agency-Specific

Federal agencies have specific policies on this that are appropriately tailored to the specific nature of their programs. Section 200.112 (link is external) requires Federal agencies to have policies on conflict of interest in Federal awards and requires non-Federal entities to disclose in writing any potential conflicts of interest (in accordance with applicable policies) to the Federal awarding agency or pass-through entity.  COFAR FAQ .112-1 (link is external) specifies that this clause refers to conflicts related to how decisions are made for selecting subrecipients or procurement contracts.

Impact at the University of Massachusetts:

  • The impact at UMass will remain an open issue until individual federal agencies have published their Implementation Plans.

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Internal Controls §200.303 (link is external)  

The non-Federal entity must:

(a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).

(b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards.

(c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards.

(d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings.

(e) Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive or the non-Federal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws regarding privacy and obligations of confidentiality.

Impact at the University of Massachusetts:

  • The Uniform Guidance places strong emphasis on internal controls to reduce the risk of waste, fraud, and abuse in the stewardship of federal funding. Internal controls are the organizational processes we implement to ensure operational effectiveness and efficiency, reliability of internal and external reporting, and compliance with applicable laws and regulations.
  • UMass is required not only to have effective internal controls, but to communicate and follow them. We must also monitor compliance and take action when we identify issues. PIs,  business managers, and central offices will need to collaborate to meet these requirements. This will include stronger efforts to limit cost transfers and late salary transfers, to practice effective financial review and control throughout the award period and to adequately document transactions.

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License Fees and Royalties covered by Bayh-Dole exempt from Program Income

Policy Guide on Profit (200.400 (link is external)).  Entities may not earn or keep profit resulting from Federal financial assistance, unless expressly authorized by the terms and conditions of the Federal award.

Program Income (200.307 (link is external)).  The Uniform Guidance does not include language limiting the treatment of licensing/royalty revenue as program income (A-110, .24(h)), which is inconsistent with Bayh-Dole Act.  In FAQ .307-1 (link is external), COFAR clarified that “U.S. law or statute takes precedent over the Uniform Guidance.”  Therefore, income from license fees and royalties on research funded by a Federal award should be excluded from the definition of program income.

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Budget Preparation and Cost Principles

Participant support costs must be tracked in a separate account  Section 200.75 (link is external).

  • Participant support costs are direct costs such as stipends or subsistence allowances, travel allowances and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects.
  • Participant support costs should be excluded from the MTDC.  See also MTDC.

    Impact at the University of Massachusetts:
    UMass requires projects to track participant support costs in a separate sub account.

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Compensation-Personal Services and Institutional Base Salary Section 200.430 (link is external)

  • Institutional Base Salary or IBS is annual compensation paid for an individual's appointment (9 or 12 months), whether that individual’s time is spent on research, teaching, administration, or other activities. IBS does not include supplemental payments (one time or recurring), administrative supplements and/ or compensation for special programs and activities. Additionally, IBS does not include payments from other organizations or income that individuals are permitted to earn outside of their institutional responsibilities, such as consulting.
  • IBS rate must be used as the base salary on all grant proposals. For effort reporting purposes, total institutional effort is 100% effort, regardless of the individual’s appointment (e.g., 0.5 FTE, .625 FTE, 1.0 FTE). No individual may commit more than 100% institutional or summer effort or be compensated at a rate that would exceed their annualized institutional base salary.

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Administrative costs may be charged as direct costs under certain conditions.

  • Administrative or clerical salaries and expenses are allowed as direct costs when the activities are integral to a project, can be specifically identified, are included in the budget or have prior approval, and are not also recovered as indirect costs (Section 200.413 (link is external) and 200.430 (link is external)).  “Integral” is defined as essential to the accomplishment of the project’s goals and objectives, rather than necessary for the overall operation of the institution.

    Impact at the University of Massachusetts:
    In order to charge administrative and/or clerical costs to federally sponsored agreements, a determination must be made that the need is based on the specific project being defined as a Major project and the cost is not part of the indirect cost base.  Because the CAS Policy takes precedence, these expenses must be in line with the current CAS Policy in place until such time it may be resubmitted.

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Computing Devices allowed as a Supply – Chargeable as a Direct Cost

  • Cost of Computing Devices: Section 200.453 (link is external) allows computing devices to be charged as direct costs if they are essential and allocable, but not solely dedicated, to the performance of a Federal award.
  • Section 200.20 (link is external) defines a computing device as a “machine 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.”  To be considered a supply cost, the cost of the computing device may not be equal to or exceed $5,000.  

    Impact at the University of Massachusetts:
    Computing devices should be itemized in your proposal budget and their use in the project clearly justified in the budget justification.
    The PI is required to evaluate and ensure that the project does 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.

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Payouts for Accumulated Leave and Compensation Claims are Allowable

  • Section 200.431 (link is external) The cost of compensation paid to employees for authorized absences, payments for unused leave when an employee retires or terminates employment, and actual claims for workers compensation, unemployment compensation, severance pay, and similar benefits are allowable as indirect costs.  Cost must be recognized in the period that the leave is taken and paid for when the entity uses the cash basis of accounting.

    Impact at the University of Massachusetts:
    UMass does not currently charge federal awards in these instances.

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Publication Costs after the Period of Performance are Allowable

  • Publication and Printing Costs: Section 200.461 (link is external) clarifies that non-Federal entities may charge the Federal award before closeout for the costs of publication or sharing of research results if the costs are not incurred during the period of performance of the Federal award.

    Impact at the University of Massachusetts:
    In developing your proposal, make sure that the costs for publication and printing are specified in the budget.  The budget justification should include an explanation of why the costs will be incurred post-award.
    Departments must work with the Controller’s Office and OGCA regarding the charging of these costs after the termination of the award.  Costs must be charged within 90 days of termination.

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Short-term Travel Visas for Recruitment are Allowable as Direct Costs

  • Short-term travel visas in connection with recruitment efforts are allowable as direct costs provided they can be clearly identified as directly connected, critical and necessary to the project. (Section 200.463 (link is external) Recruiting Costs (d)).

    Impact at the University of Massachusetts:
    Departments must maintain documentation supporting this cost in accordance with the UG requirements.
     

Travel Costs for Conferences
 

  • Family-Friendly policies in regards to travel costs: Section 200.474 has been amended to allow the cost of identifying, but not providing, temporary locally-available dependent care resources for travel to conferences.  If the institution implements a policy that these costs are allowed, the policy must be implemented consistently across all sources of funds.  Travel costs for dependents are unallowable, except for travel lasting 6 months or more.  Must have prior approval from the awarding agency.  (Section 200.474(2) (link is external)).
  • Conference Costs: Section 200.432 (link is external) confirms that costs associated with intra-campus meetings are unallowable.

    Impact at the University of Massachusetts:
    UMass does not currently have a policy which allows for the direct charging of costs associated with identifying dependent care resources for travel to conferences.

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Allowable Expenses for Foreign Activities

  • Exchange Rates: Cost increases due to fluctuations in exchange rates are allowable subject to the availability of funding and prior approval. The institution must review local currency gains to determine the need for additional funding before the expiration date of the award.
    (Section 200.440 (link is external)).
  • Value Added Tax (VAT) is an allowable expense if it is charged for the purchase of goods or services and the non-Federal entity is legally required to pay in country.  Any refunds or applicable credits resulting from the payment of VAT taxes must be credited to the awarding agency
    (Section 200.470 (link is external)).

    Impact at the University of Massachusetts:
    If applicable, additional documentation for foreign subrecipients may be needed to demonstrate requirement ‘to pay in country VAT tax’.

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New Exclusions from MTDC

Modified Total Direct Cost (MTDC) should only include salaries and wages, fringe benefits, materials and supplies, services, travel, and subgrants up to the first $25,000 of each subaward (regardless of the period covered).  Specifically excluded from the MTDC are equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs and the portion of each subaward in excess of $25,000.  (Section 200.68 (link is external))  The Uniform Guidance further excludes participant support costs and rental costs.

Impact at the University of Massachusetts:

  • UMass already requires projects to track participant support costs in a separate sub- accounts.
  • The MTDC is the basis by which Facilities and Administrative (F&A) costs are charged to federal awards.   F&A rates are negotiated campus-wide.

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Change Requests Handled by Your OGCA Award Administrator

Budget Revisions must receive prior approval. (Section 200.308 (link is external))

These include:

  • Changes in the amount of approved cost-sharing.
  • Transfer of funds budgeted for participants support costs to other categories of expense.
  • Subawarding, transferring, or contracting that was not described in the application and funded in the approved award, except for supplies, materials, equipment, or general support services.

Disengagement from the project for more than three months or a 25% reduction in time devoted to the project by the approved project director or principal investigator requires prior approval.  Disengagement refers to the level of the PI’s involvement with project activities, not the PI’s actual presence on campus.

Other Modifications Requiring Pre-Approval are the Same.  Modifications that continue to require pre-approval (under the OMB Circulars and the Uniform Guidance) are: change in the scope or objective of the project, change in key personnel specified in the application, and the inclusion of costs that require prior-approval.

Section 200.308(d) (link is external). Prior written approval for certain costs can be waived by the agency. 

Impact at the University of Massachusetts:

To initiate a change in your program plan or budget after award, contact your OGCA Award Administrator 

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Subrecipients

Contractor vs Subaward

  • Elimination of the term Vendor and replaced with Contractor.  See Sections 200.22 Contract (link is external), 200.92 Subaward (link is external), and 200.330 Subrecipient and Contractor Determinations (link is external).  Determination must be documented.
  • Subaward: A subaward is for the purpose of carrying out a portion of the Federal award and creates a Federal assistance relationship with the subrecipient.  Subawards are subject to F&A up to the first $25,000 of the award for the entire period of performance.
  • Contractor: A contract is for the purpose of obtaining goods and services and creates a procurement relationship with the contractor.  The entire contract amount is subject to F&A. 

Subrecipients: De Minimis indirect cost rate (F&A) of 10% of MTDC should be applied to non-federal entities without a negotiated indirect cost rate (F&A) (Sections 200.210 (link is external), 200.331 (link is external), and 200.510 (link is external)).

Fixed Amount Subawards. (200.332 (link is external)). With prior approval, fixed amount subawards may be awarded up to the Simplified Acquisition Threshold.

Impact at the University of Massachusetts:

Your OGCA Proposal and/or Award Administrator can help you make the determination of whether a subrecipient is a subaward or a contractor.  Read more:

Subcontractor vs Vendor (Contractor) vs Consultant

1. A Subcontractor is distinguished from both a vendor and a consultant in that a Subcontractor:

a. Performs a substantive portion of the proposed Statement of Work incorporated into the Prime Contract;

b. Has responsibility for internal programmatic decision-making and design;

c. Is responsible for assisting the Prime Recipient in meeting the goals of the project;

d. Is responsible for adhering to applicable Federal programmatic compliance requirements;

e. Retains intellectual property and copyright to the work produced by the Subcontractor’s personnel; may co-author an article in a professional research journal.

f. Note: OGCA does not issue Subcontracts to individual persons; only to a company or organization.

2. A Vendor is issued a Purchase Order based on a request sent by an administering unit to the University’s Procurement Office. The purchase of goods and services, including “Consulting Services”, are obtained from a commercial vendor.

a. A Vendor provides similar goods and services to multiple customers as part of their routine business operations;

b. A Vendor competes for customers with other like providers;

c. A Vendor does not retain intellectual property or copyright to the deliverables;

d. Cost sharing is not required of a Vendor;

e. Joint authorship of publications is not sought by Vendors;

f. The general terms of the Prime Contract do not flow down to the Vendor.

3. A Consultant may be an individual or a commercial entity and is a type of Vendor paid through a Purchase Order issued by the Office of Procurement.

a. A Consultant’s deliverable may be intermittent throughout the project, is not clearly defined and similar other work is performed by that Consultant commercially on a routine basis;

b. A Consultant’s deliverables do not ordinarily generate patentable or copyrightable results of an original or substantive nature;

c. A Consultant is not subject to the compliance requirements of the Prime Contract;

d. A Consultant’s fee is based on an hourly or daily rate which is provided and explained in a Consultant rate proposal;

e. A Consultant’s services are on a “work for hire” basis and all intellectual property or copyrightable rights are assigned to UMass by the Consultant;

f. A Consulting Firm is a commercial entity whose regular business activity is to provide services similar to those proposed under the current project.

g. An Individual Consultant is a non-UMass employee hired to provide technical expertise in support of a sponsored research project. As a general rule, the activities performed by a non-UMass faculty member who is named as an individual Consultant in a proposal must fall outside of the individual’s normal academic duties and cannot make use of his/her institutional facilities, personnel or students. If these criteria are not met, then the faculty member’s home institution should appear as a Subcontractor in the UMass proposal rather than an individual Consultant.

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Terms and Conditions for Subrecipients

Uniform Guidance is Applicable to Subrecipients: Subrecipients receiving flow down from a federal award are subject to the Uniform Guidance.  (Section 200.101 (link is external)).

Subcontracts under Federal Awards: Contracts over the Simplified Acquisition Threshold ($150,000) must address contract breach.  Contracts in excess of $10,000 must address termination for cause.  (Appendix II to Part 200 – Contract Provisions for Non-Federal Entity Contracts under Federal Awards (link is external)).

Federal cost-reimbursement contractsawarded under the FAR are subject to Subpart A, Subpart B, Subpart D (Post Federal Award Requirements and Subrecipient Monitoring and Management), Subpart E and Subpart F.

Impact at the University of Massachusetts:

Contracts for subrecipients of federal awards administered by UMass will include specific terms and conditions applicable to the Uniform Guidance.

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Pass through Entities Must Assess Risk

Section 200.331(b) (link is external) Entities receiving federal awards who then subaward to other entities must consider the risks associated with that subaward combined.

Impact at the University of Massachusetts:

Risk assessments for all subrecipients of federal awards will be conducted by OGCA.  PI’s should be very careful in the selection of the entities they choose and evaluate their experience in working on federally funded projects prior to this relationship.  Less experience will result in the need for more oversight and management by the PI, OGCA and the Controllers Office; refer to excerpt below:

(e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals:

(1) Providing subrecipients with training and technical assistance on program-related matters; and

(2) Performing on-site reviews of the subrecipient's program operations;

(3) Arranging for agreed-upon-procedures engagements as described in §200.425 Audit services.

(f) Verify that every subrecipient is audited as required by Subpart F—Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in §200.501 Audit requirements.

(g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records.

(h) Consider taking enforcement action against noncompliant subrecipients as described in §200.338 Remedies for noncompliance of this part and in program regulations.

[78 FR 78608, Dec. 26, 2013, as amended at 79 FR 75885, Dec. 19, 2014]

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Monitoring Required by Section 200.331 Mostly Unchanged

Oversight should be based on the consideration of risk (see above).

Monitoring should include the review of performance and financial reports required of the subawardee to meet the requirements of the federal award. 

When Deficiencies are Identified: The subrecipient should take timely and appropriate action to correct deficiencies pertaining to the federal award.  Unresolved deficiencies may result in the issuance of a management decision for audit findings.  (Section 200.521 (link is external))

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Reporting Requirements

Effort Reporting Premised on Strong Internal Controls     

Section 200.430(i) (link is external). Emphasis on documenting salary charges to federal awards using a system premised on strong internal controls which provides reasonable assurance as to the accuracy of the information. The institution’s official payroll system should be the basis for confirming payroll charges to federal awards.

Impact at the University of Massachusetts:

UMass will continue to track paid effort via the ECRT Effort Reporting System.

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Retain Records for 3 Years after Closeout.  Electronic Retention is Preferred

  • Record Retention.  Section 200.333 (link is external) clarifies the requirement that records be retained for three years from the date of submission of the final expenditure report and permits the federal agency to extend the retention period if notified in writing.
  • Storage of Information.  Section 200.335 (c) (link is external) makes clear that electronic, open, machine readable information is preferable to paper as long as there are appropriate controls in place to safeguard from alteration of records.

Impact at the University of Massachusetts:

The Uniform Guidance provides an opportunity to shift from paper to electronic methods of storage. It encourages federal agencies and universities to use electronic formats rather than paper whenever practicable. While we must still provide or accept paper when it is requested, the guidance says that when original records are electronic and non-alterable, there is no need to create and retain paper copies. Similarly, when original records are paper (e.g. receipts), electronic versions (e.g. pdf scans) may be substituted provided they remain readable, are subject to periodic quality control reviews and are reasonably safeguarded against being altered.

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Stronger Closeout Requirements and Enforcement Techniques

Subpart D - Subtitle VII Closeout.  Section 200.343 (link is external) – provide all reports and liquidate all obligations incurred within 90 days.  Includes subrecipient invoices and cash payments.

Section 200.201 (link is external): Requires that the institution certify that project was completed and/or level of effort was expended.  If not carried out fully, the award will be adjusted.

Enforcement Techniques:

  • Withholding future awards
  • Inability to draw down funds beyond 90 calendar days after award end date

Increase in the Single Audit Threshold and Remedies for Noncompliance:

Subpart D - Subtitle VII Remedies for Noncompliance. Section 200.339 (link is external) allows the termination of funds for cause.

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Audit

Section 200.501 (link is external) Audit Requirements raises the Single Audit Threshold from $500,000 in Federal expenditures per year to $750,000 in Federal expenditures per year. This reduces the audit burden for approximately 5,000 non-Federal entities while maintaining Single Audit coverage over 99% of the Federal dollars currently covered.

Impact at the University of Massachusetts

Additional risk assessment tools required for subrecipients under Single Audit threshold ($750k)

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