OMB Uniform Guidance
The federal Office of Management and Budget (OMB) has made a major change to the underlying guidance by which university recipients of federal awards have operated for decades. OMB combined eight separate circulars, applicable to different types of grantee organizations, into a single document, "CFR Title 2, Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards," commonly referred to as the Uniform Guidance (UG).
The three previous circulars applicable to universities are: A21 – Cost Principles for Educational Institutions, A110 – Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and other Non-profit Organizations and A133 – Audits of States, Local Governments and Non-Profit Organizations. There are similar documents applicable to states, local governments and Indian Tribes. The UG includes portions from all of the previous documents as well as new sections and some deletions. While much of it is similar to the previous guidance, there is the potential for both major and minor changes to university recipients of federal awards. In addition, the OMB document is actually guidance to federal agencies and each granting agency must issue its own implementing regulations. While agency implementation plans were due to OMB in June, final versions have not yet been published.
The effective date is December 26, 2014 and is applicable to new grants and funding increments.
The UG encompasses a wide variety of compliance areas, including what constitutes an allowable charge to a federal award, what costs may be included in the Facilities and Administrative Cost Rate, minimum information required in funding announcements, information needed in equipment records, how long records must be retained, requirements for monitoring subrecipients, the frequency and minimum content of programmatic reporting and a host of other topics.
The University of Delaware must be compliant with the UG in order to remain eligible to receive federal awards. The University’s comprehensive implementation plan is described below. The University community will be kept informed of progress through this website, the research-admin listserv, the newly created UD Research Administrators E-Newsletter and topic specific trainings. Your participation and feedback is encouraged.
In preparation for the December 26th, 2014 implementation date, we have created working groups based on each of the subparts and the appendices. Each working group has a chair, as well as representation from colleges and central administration (including staff from outside of the research community for some parts). The groups are 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. Work plans and other materials will be posted as they become available.
- University of Delaware: Implementation of new uniform guidance (Revised 11/12/2014)
- University of Delaware: Implementation Timeline (Revised 9/22/2014)
- COGR Guide to the OMB Uniform Administrative Requirements,
Cost Principles, and Audit Requirements for Federal Awards (Revised 9/17/2014)