The new Uniform Guidance rules are a topic so confusing and hard to decipher, this article gives merely an introduction and overview — as well as some resources for you — as you begin to wade through the maze. Next month, we will discuss the impact these new rules may have on your organization.
According to the Federal Office of Management and Budget, any state or local government entity interested in developing a grant project, creating a grant application and managing a federal grant must begin to wade their way through the new rules published in May of 2014. These changes will impact the way you develop your budget, costs and the administration of all grants.
According to the Office of Management and Budget (OMB), the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly called “Uniform Guidance”) was officially implemented in December 2014 by the Council on Financial Assistance Reform (COFAR).
The Uniform Guidance — a government-wide framework for grants management — synthesizes and supersedes guidance from earlier OMB circulars. The reforms that comprise the Uniform Guidance aim to reduce the administrative burden on award recipients and, at the same time, guard against the risk of waste and misuse of Federal funds.
1. Among other things, the OMB’s Uniform Guidance does the following:
• Removes previous guidance that is conflicting and establishes standard language
• Directs the focus of audits on areas that have been identified as at-risk for waste, fraud and abuse
• Lays the groundwork for Federal agencies to standardize the processing of data
• Clarifies and updates cost reporting guidelines for award recipients
2. Examples of the changes impacting state and local entities include:
• Additional prior written approvals have been added for those grants, which require prior pre-award approvals for budgeted purchase costs, equipment, etc.
• Documentation for how each individual’s travel is necessary to the federal award of the grant
• All grantees must have robust internal controls documented and followed to ensure compliance with the terms conditions and regulations of the award
• Electronic records are preferred to paper records
• Computing devices under $2000 are considered supplies, while $2001 or more are considered general purpose equipment
• Administrative and clerical salaries may be allowable as direct costs if the work is necessary for the project and the sponsor specifically approves the cost
• Costs incurred prior to the effective date of the award must be necessary for efficient and timely performance of the award
3. Important resources to help you understand the changes:
• 2 CFR 200 – Uniform Guidance (Note: the CFR will be updated to reflect the technical corrections and changes to agency regulations after the December 26th effective date.)
• Joint Interim Final Rule Implementing the Uniform Guidance
• Blog Post Announcing Implementation of the Uniform Guidance
• Uniform Guidance Crosswalk for Federal Agency Exceptions and Additions
• Preamble and Original Federal Register Notice for Uniform Guidance (78 FR 78589)
• Frequently Asked Questions (updated as of November 2014)
• Uniform Guidance Crosswalk from Predominant Source in Existing Guidance (29 pages)
• Uniform Guidance Crosswalk to Predominant Source in Existing Guidance (10 pages)
• Uniform Guidance Cost Principles Text Comparison (174 pages)
• Uniform Guidance Audit Requirements Text Comparison (46 pages)
• Uniform Guidance Definitions Text Comparison (76 pages)
• Uniform Guidance Administrative Requirements Text Comparison (123 pages)
• M-13-17 Next Steps in the Evidence and Innovation Agenda
• M-14-17 Metrics for Uniform Guidance
Your organization may need a team to walk through the changes, in order to understand the nuances in the rules. The Department of Justice, the Office of Justice Programs nor the grants.gov website offer any further explanation other than what is provided here. The Crosswalk documents above are a good place to start as a summary of the changes that will impact you as a state or local government. An in-depth review is needed for any grant applications currently being considered.
Next month, we’ll review in greater detail the impact on law enforcement by the UGG.
