New - OMB Uniform Guidance

Background

The Uniform Guidance ("UG") is the single biggest regulatory change in the last 50 years of research administration. This guidance to federal agencies consolidates and replaces eight Office of Management and Budget (OMB) Circulars. It combines those circulars for Institutions of Higher Education--A-110 (Administrative requirements), A-21 (Cost principles), and A-133 (Audit requirements)--with those companion circulars applying to state and local governments, Indian tribal governments, and non-profits.

The UG came about as a result of President Obama's February 2011, directive to OMB to reduce unnecessary regulatory and administrative burdens. In October 2011, OMB created the Council on Financial Assistance Reform ("COFAR"). This is an interagency group which includes OMB, HHS, NSF, COGR, and others. Their activities include providing recommendations to OMB on actions necessary to effectively deliver and oversee grants and cooperative agreements.

On December 26, 2013, 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). The implementation date for this regulation is December 26, 2014 for all parts except for those relative to audit requirements. Federal agencies (NIH, NSF, Dept. of Energy, etc.) must develop their own agency-specific policies that conform to the Uniform Guidance. Existing federal awards will continue to be governed by their original terms and conditions. Once the Uniform Guidance goes into effect, it will apply to awards or funding increments issued on or after that date.

The University of Illinois System must adopt the new regulations and agency policies, and therefore must review its current policies and procedures to ensure they are consistent with the new guidance. We will modify our policies and procedures as necessary and use this new regulation as an opportunity to update our existing practices. Our plan is to work together across all campuses on this initiative.

Navigating the Uniform Guidance

The Uniform Guidance is broken down into Subparts. The preamble also provides a useful framework and discussion of how certain guidelines were ultimately determined.

Preamble - Major Policy Reforms
Subpart A - Acronyms and Definitions
Subpart B - General Provisions
Subpart C - Pre Award Requirements
Subpart D - Post Award Requirements
Subpart E - Cost Principles
Subpart F - Audit Requirements

Agency Updates

April 8, 2015: NSF has issued a set of frequently asked questions (FAQs) on the Foundation's implementation of 2 CFR § 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards(Uniform Guidance).  These FAQs are available on the NSF DIAS/Policy Office website.

March 24, 2015: The Department of Education has created a new webpage dedicated to the Uniform Guidance regulations that took effect in December: http://www2.ed.gov/policy/fund/guid/uniform-guidance/index.html. We encourage you to visit the site, which includes a variety of technical assistance resources including training and FAQs.

March 13, 2015: A table of the circulars that have been consolidated into the Uniform Guidance can be found at the following link which includes the current DOJ Financial Guide: http://ojp.gov/financialguide/GeneralInformation/chapter2page2.htm. 

Prior to implementation of the Uniform Guidance on December 26, 2014, each federal agency is required to finalize an agency implementation plan with OMB.

The National Science Foundation (NSF) released a draft version of their Implementation Plan for the OMB Uniform Guidance on May 9th, 2014. The draft version of the NSF PAAP Guide can be accessed at the following link: National Science Foundation draft version

Announcement: NIH Interim General Grant Conditions Implementing New HHS Grants Regulations (Uniform Guidance)

Other agency plans will not be available until shortly before the implementation date.

University of Illinois System's Implementation

In general, the University of Illinois System's strategy for the implementation of the Uniform Guidance has been to establish a task force and working groups with participation from all three universities to assure compliance with these new federal regulations, and align our processes and procedures where feasible. We have included all those central offices responsible for management and monitoring of grant proposals and awards in this process so far—many units within the Office of Business and Financial Service (OBFS) and the Office of the Vice Chancellor of Research (OVCR), with assistance from Internal Audits.

We began by creating a task force responsible for monitoring and guiding the analysis and implementation phases of the Uniform Guidance among all three campuses. That task force meets every two weeks, and is made up of the following personnel:

UIUC: Shelly Benson, Director of Government Costing; Ruth Boardman, Associate Director, Grants and Contracts; Kathy Dams, Asst. Director in the Office of Sponsored Programs; Darla Hill, Director of University Audits; Linda Learned, Associate Director, Office of Sponsored Programs

UIS: Rebecca Jones, Asst. Director of Grants & Contracts

UIC: Karen McCormack, Senior Associate Director, Grants and Contracts; Mee Mee Lee-Choi, Associate Director, Grants and Contracts; Patti Pfister, Associate Director, Office of Research Services; Jennifer Rowan, Executive Director, Research Admin and Operations

The task force created the timeline for completion of various tasks within the analysis and implementation phases, including target dates for new and revised policies and procedures. They also formed independent university section teams to perform a detailed review the UG sections—focusing on those issues that are "high impact" and priority.

The universities will focus on these high-impact sections -those that will have a more widespread effect on the faculty and on management of the awards in the coming weeks. The table below represents those high impact topics identified by the system, and the staff assigned the task of in-depth analysis and drafting resultant policies and procedures. Although our current focus is on these high-impact sections, the implementation phase will be ongoing and will include addressing all areas of the Uniform Guidance, focusing on the procurement sections next. COFAR's 9/9/2015 FAQs granted a grace period until Fiscal Year 2017 for implementation of the procurement sections, thus we plan to partner with OBFS Purchasing in early 2015 to begin working on this initiative.

High Impact Topic	UG Sections	Meeting Lead	UIC	UIUC	UIS
Subawards - Request and Award Process Risk Assessment Monitoring	200.330 -200.332 200.501 200.521	Amy Brooks	LaShawnda Hall Karen McCormack Patti Pfister Katina Shepherd	Julie Robinson Missy Beck-LeFaivre Amy Brooks Charles Alsbury Kristie Lamoreux	Rebecca Jones Kathleen Furr
Cost-Sharing/ Compensation	200.306 200.308 200.204 200.430	Mee Mee Lee-Choi	LaShawnda Hall Mee Mee Lee-Choi Karen McCormack Patti Pfister	Geoff Dehler Jayne Goby Linda Gregory	Rebecca Jones Kathleen Furr
Direct Costs (select items of cost - computing devices, admin salaries)	200.314 200.453 200.413	Karen McCormack	Etzer Cantave Maureen Johnson Katrina Lopez Karen McCormack Patti Pfister	Jayne Goby Ruth Boardman Shelly Benson	Rebecca Jones
Close-Outs	200.343 200.301	Etzer Cantave	Etzer Cantave Mee Mee Lee-Choi Joe Stefanich	Linda Gregory Alison Morgan	Rebecca Jones
Program Income	200.307	Kathy Dams	Etzer Cantave Joe Stefanich Mee Mee Lee-Choi	Kathy Dams Sarah Lorbiecki	Rebecca Jones

Last Updated: July 24, 2018