<b>The Uniform Guidance: Federal Grant-Making Reform</b>
The Uniform Guidance: Federal Grant-Making Reform

With a little more than a year under its belt, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards has streamlined federal grants management – but not without the necessity for significant changes in practices among grantees receiving federal funds. Issued by the Office of Management and Budget and put into effect at the end of 2014, the purpose of the “Uniform Guidance” is to reduce the risk of waste, fraud and abuse by increasing assurance that federal resources achieve evidence-based outcomes. To get you up to speed, here are highlights that represent just some of the changes from the previous federal regulations:

  • There are now three tiers of requirements:
    • Federal requirements (those in the Uniform Guidance)
    • Agency-specific (“Agency Plans”): Remember, there are 26 federal grant-making agencies, each with their own pre- and post-award nuances.
    • Award-specific: Some awards contain more prescriptive requirements for the content and due dates of progress reports. It is critical to read your award letter carefully!
  • For travel costs, documentation of each individual’s travel is required.
  • Additional written prior written approvals have been added. To track project and budget deviations, grantees must seek prior approval from the awarding federal agency if:
    • The project changes in scope or objective (even if the budget is not impacted)
    • There is a change in key personnel specified in the application or award document
    • The approved project director or principal investigator is absent more than three months or there is a 25 percent reduction in their time devoted to the project
    • The awardee plans to transfer amounts between indirect and direct costs, or vice versa, or transfers funds originally intended for training allowances
    • Funds are sought for costs that require approval in accordance with OMB UG Part 200
    • A sub-award, transfer or contracting out (“contractor” has replaced “vendor”) of any work isn’t described in the application and funded in the approved award (with the exception of purchasing supplies, material, equipment and general support services).
  • Less emphasis on cost-sharing. In fact, voluntary cost sharing may no longer be used as a review criteria!
  • More emphasis on internal monitoring. To assure that charges are accurate, allowable, and properly allocated, he Uniform Guidance requires awardees to comply with a “stringent framework of internal control objectives and requirements.” This involves an emphasis on consistent and written policies, as well as a focus on processes to reflect on the work performed.
  • 90-day deadline for closeout reports. When your grant term is up, you must submit your final reports within 90 days.
  • Computing devices costing $2,000 or more are now considered equipment, rather than supplies.
  • Easier reimbursement for indirect costs. Organizations without an indirect cost rate agreement may now use a standard minimum rate to support the operations of their proposed project.