Uniform Guidance Implementation at the University of Louisville
What is the Uniform Guidance?
In December 2013, the White House's Office of Management and Budget (OMB) announced a sweeping reform of the guidance regarding Administrative Requirements, Cost Principles, and Audit Requirements for Federal awards into a single circular. The new “Uniform Guidance” streamlines the language from eight existing OMB circulars (including A-21, A-87, A-110, and A-133) into one consolidated set of guidance in the Code of Federal Regulations. This new Guidance was implemented by Federal agencies for new funding received on or after December 26, 2014.
The National Council of University Research Administrators (NCURA) has stated that the Uniform Guidance is “the single biggest regulatory change in the last 50 years of research administration.” The Uniform Guidance Implementation Workgroup was established by the Office of the EVPRI to research the revised regulations and, in conjunction with other University offices, determine what will be needed to keep the University of Louisville and our research faculty compliant for Federal funding. As we understand what procedural changes will be required, the Uniform Guidance Implementation Workgroup will be able to provide guidance and instruction to our research faculty and staff so that we are well-prepared for this new era in federal award management.
*Apr 8, 2015: The National Science Foundation (NSF) has issued a set of Frequently Asked Questions on its implementation of Uniform Guidance 2 CFR part 200. This FAQ resource will be updated periodically by the NSF as more questions arise.
Apr 1, 2015: The National Institutes of Health has published its full revised Grants Policy Statement, effective for all NIH grants and cooperative agreements with budget periods beginning on or after December 26, 2014. In addition, the NIH has also provided a supplemental Summary of Significant Changes document, which helps explain the changes in the full-text policy.
Mar 20, 2015: The National Institutes of Health’s webinar from March 12, “Q&A: Eye on NIH Policy – OMB Uniform Guidance, What it Means for You” video is now available online at the NIH YouTube channel. This webinar features discussion on frequently asked questions that were submitted in response to NIH’s Interim Grant General Conditions document and the related video “NIH Implementation of Uniform Guidance.”
The Uniform Guidance Implementation Workgroup has published its Analysis of Federal Uniform Guidance. This reference cites specific text of 2 CFR part 200 Uniform Guidance and provides the analysis and discussion for implementation at the University of Louisville.
Mar 5, 2015: The National Institutes of Health has announced an upcoming webinar - Eye on NIH Policy: OMB Uniform Guidance, What it Means for NIH & You. The webinar is scheduled for Thursday, March 12 from 1:30 – 2:30 pm. This is an interactive webinar with participant discussion and a Q&A session. In advance of the webinar, the NIH has released a pre-recorded video presentation “NIH Implementation of Uniform Guidance”, which is available on the NIH Grants YouTube channel. Any questions you may have from this presentation may then be submitted during the webinar for discussion.
UofL Community Presentations
In February 2015, the Uniform Guidance Implementation Workgroup hosted a series of four Information Sessions on Uniform Guidance at both Health Science and Belknap campuses. The slides from this presentation are now available as a reference for the entire UofL community.
UofL Online Resources for Uniform Guidance Implementation
- Uniform Guidance Quick Reference (pdf)
- Uniform Guidance FAQ (pdf)
- Analysis of Federal Uniform Guidance (pdf)
- Federal Agency Reference Guide for Uniform Guidance (pdf)
- Subaward / Contractor Determination Checklist for Federal Awards (pdf)
- Subrecipient Commitment Form (pdf)
Key References for Uniform Guidance
Federal Code – Office of Management and Budget (White House)
- Joint Interim Final Rule Implementing Uniform Guidance for all Federal award-making agencies (pdf)
- 2 CFR Part 200 “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award” (pdf)
- 2 CFR Part 200 “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award” (web)
National Institutes of Health
- NIH Grants Policy Statement, ver. March 31, 2015, 3/31/2015 (pdf)
- NIH “Summary of Significant Changes to the NIH GPS for March 2015 Version”, 3/31/2015 (pdf)
- NOT-OD-15-087 “Publication of the Revised NIH Grants Policy Statement (Rev. 3/31/2015)”, 3/31/2015 (web)
- Presentation: “Q&A: Eye on NIH Policy – OMB Uniform Guidance, What it Means for You”, 3/16/2015 (pre-recorded video)
- Presentation: “NIH Implementation of Uniform Guidance”, 2/24/2015 (pre-recorded video / slides only)
- NIH Frequently Asked Questions – Uniform Guidance and the NIH Interim Grant Conditions, 2/5/2015 (web)
- NOT-OD-15-065 “NIH Interim General Grant Conditions Implementing New HHS Grants Regulations (Uniform Guidance)”, 2/5/2015 (web)
- NOT-OD-15-046 “Publication of Interim Final Rule Adopting OMB’s Final Guidance in 2 CFR Part 200 into HHS’ Implementing Regulations at 45 CFR Part 75”, 12/19/2014 (web)
National Science Foundation
- NSF Frequently Asked Questions, 4/7/2015 (pdf)
- NSF Webinar slides for Proposal & Award Policies & Procedures Guide from Jan 27, 2015 (pdf)
- Revised Grants.gov Application Guide (pdf)
- Revised Proposal & Award Policies & Procedures Guide (web)
- Significant Changes and Clarifications to the PAPPG (web)
Council on Financial Assistance Reform (COFAR)
- 2 C.F.R. 200 Uniform Guidance (web)
- Frequently Asked Questions for New Uniform Guidance, Updated November 2014 (pdf)
Uniform Guidance Implementation Workgroup
Kevyn Merten, Ph.D. - Assistant Vice President for Research & Innovation
Cheri Jones - Director, Audit Services
Judy Bristow - Director, Office of Sponsored Programs Administration
Julie Renn - Assistant Director, Office of Sponsored Programs Administration
Larry Zink - Controller and Treasurer
Andrew French - Grants Management Specialist, Office of Sponsored Programs Administration
If you have any questions, requests, or concerns regarding the new federal regulations and how they will be applied at UofL, please contact our Workgroup by email at firstname.lastname@example.org.
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Last update: 4/8/2015