Q: Where can I find the Uniform Guidance?

A: In the Code of Federal Regulations - CFR 200

Q: Do I follow the old OMB Circulars or the Uniform Guidance?

A1: If your funding was issued prior to December 26, 2014 you should follow the old OMB Circulars unless the award has been expressly amended to incorporate the Uniform Guidance. However…
A2: Beginning July 1, 2015, ALL federally funded awards will follow the Uniform Guidance, regardless of the date they were awarded.

Q: I heard that the Uniform Guidance requires that “price or rate quotations must be obtained from an adequate number of qualified sources” for purchases over $3,500. What do I have to do to comply with this requirement?

A: Implementation of the new Uniform Guidance procurement standards has been delayed until July 1, 2017, so for now you may continue to operate under the procurement requirements of OMB Circular A-110.

Q: The Uniform Guidance allows entities without an approved F&A rate to use 10% of Modified Total Direct Costs, but NIH used to require that foreign subrecipients use an F&A rate of 8% of Total Direct Costs. Which F&A rate should I use?

A1: In accordance with section 200.414 of the Uniform Guidance any non-Federal entity that has never received a negotiated indirect cost rate may elect to charge a de minimis rate of 10% of modified total direct costs (MTDC) which may be used indefinitely.
A2: NIH clarified that it will require foreign NIH subrecipients to continue using an F&A rate of 8% of Total Direct Costs minus equipment.

Q: What is happening with the Federal Research Terms and Conditions?

A: The Federal Research Terms and Conditions (RTC’s) are currently being revised by each agency.

Q: The Uniform Guidance states that charging administrative/clerical staff is allowable if the staff are integral to the project and can be specifically identified with the project, and if such costs are not also recovered as indirect costs. Is this true?

A: Yes, rules governing administrative and clerical salaries require that the individuals be integral to the project or activity, be specifically identified with the project and explicitly included in the budget or have prior written approval of the Federal awarding agency. Remember that the federal agencies are responsible for implementing the terms and conditions of the Uniform Guidance, so you will need to follow the relevant agency’s implementation of the Uniform Guidance. For example, in terms of prior approval, you will need NSF’s prior approval if the cost meet the requirements above but were not explicitly in the awarded budget. In the case of NIH, you will not need their prior approval provided the costs meet the requirements above, regardless of whether they were in the awarded budget.

Q: The Uniform Guidance says we should treat computing devices under $5,000 like supplies and that the computing device does not need to be solely dedicated to performance of the funded project to which it is being charged. Do we still need to justify the purchase?

A: Yes. Think of computing devices like other office supplies (e.g. copies, postage, etc.) The Uniform Guidance requires that in order to be allowable, the circumstances for charging a computing device to a grant must be treated consistently with University policy and proactice for how other like computing devices are purchased and provided to project personnel. In addition, the computing device must be allocable to the funded project and therefore must be charged in accordance with relative benefit received by the project. In other words, you must still split the charge for a computing device amongst the various activities that the device will be used for.

Q: Under the Uniform Guidance the definition of Participant Support Costs means, “direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees.”

A: The new definition of Participant Support Costs includes both trainees and participants, regardless of status, but is limited to conferences and training grants. Look to the federal awarding agency terms and conditions for further guidance.

Q: I heard that temporary dependent care costs related to travel are allowable under the Uniform Guidance, is that true?

A: Technically, yes. However, the Uniform Guidance also states that temporary dependent care costs related to travel are only allowable if they are “consistent with (Purdue’s) documented travel policy for all entity travel.” Since Purdue does not pay from its institutional funds for such costs, temporary dependent care costs associated with travel cannot be charged to a federal grant either.

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