On December 26, 2013, the Office of Management and Budget (OMB) issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements (Uniform Guidance or 2 CFR 200) for federal awards. The Uniform Guidance streamlines and supersedes guidance previously contained in eight separate OMB Circulars. Included in the new guidance are uniform administrative requirements (pre and post-award), cost principles, audit requirements, and definitions. From the SIBCR perspective, the Uniform Guidance supersedes OMB Circulars A-110, A-122, and A-133.
SIBCR has moved forward to update its policies and procedures to comply with Uniform Guidance with the exception of the Procurement Policy for which SIBCR has accepted the one-year extension provided. The new Procurement guidelines will take effect October 1, 2018. Please see our procurement section for more information on our policy.
A steering committee has been established to implement the changes promulgated in the Uniform Guidance regulation (2 CFR 200). The Committee members include:
• Danielle Fleumer, Executive Director
• Jude Harlan, Director of Finance
• Stephen Keating, Sr. Grants and Contracts Manager
Immediate changes to be included in proposals:
Direct Charging Salaries of Administrative & Clerical Staff
SIBCR’s policy reflects section 200.413 of the Uniform Guidance, which establishes the principle that salaries of administrative and clerical staff should normally be treated as indirect costs. It also reflects the circumstances where it is appropriate to charge administrative expenses directly to federally sponsored projects. 2 CFR 200 eliminates the “major project” standard from A-122 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:
1. 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.
2. Individuals involved can be specifically identified with the project or activity;
3. Such costs are explicitly included in the budget or have prior written approval of the federal awarding agency;
• Budget justification must be included in the proposal.
4. The costs are also not recovered as indirect costs.
• Federal Register - 2 CFR 200
• Council on Financial Assistance Reform (COFAR) – 8/29/2014 Frequently Asked Questions
• COFAR's "Uniform Guidance Implementation: A Conversation Presented by the Council on Financial Assistance Reform" - Webinar