The Office of Management and Budget (OMB) UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS (The Uniform Guidance or simply UG)

The Uniform Guidance consolidates, streamlines and supersedes eight existing OMB Circulars, including Circulars A-21, A-110, and A-133 which govern the University’s costing practices and administration of federal grants and cooperative agreements. Federal contracts continue to be governed by the Federal Acquisition Regulation (FAR), Title 48 of the Electronic Code of Federal Regulations.  

The new guidance took effect on December 26, 2014 and applies to new awards and to additional funding (funding increments) to existing awards. Existing federal awards will continue to be governed by the terms and conditions under which they were awarded. This change will ease administrative burden in some areas but add a few “challenges” in others.

Each federal agency is required to promulgate its own regulations to implement the UG. So far only the National Science Foundation has published their implementation plan by way of the revised Proposal & Award Policies & Procedures Guide.  In this interim period while federal sponsors adopt their implementation plans it is difficult to assess the scope and effects of all of the changes. You may check the status of the Federal Agency Implementation Plans for the Uniform Guidance on this related web page. The Quick Guide to the Uniform Guidance is found here.

JMU Procurement Procedures under the Uniform Guidance (UG) regulations:

While JMU is working to understand, disseminate, and fully implement the Procurement Standards under the UG  (CFR200.317-326),  certain requirements like competitively bidding “micro-purchases” (those of $3,000 or more) and differentiating between named “contractors” and named “sub-recipients”  in the administrative processes governing subawards are proving administratively problematic.   Due to the complications these regulations are presenting to purchasing activities at many universities, the Office of Management and Budget has granted a grace period to allow extra time for a systematic implementation of these requirements.  Accordingly, while discussions, training, and implementation efforts will continue, the implementation schedule will result in JMU being fully compliant with these regulations no later than July 1, 2018.  In that way, all awards governed by the UG will be fully compliant with these requirements for all Fiscal Year 2019 proposals and purchases. To read the OMB announcemnt of this extension please follow this link. 

Uniform Guidance Resources from Federal Agencies:

Office of Management and Budget

  • OMB Policy Statements: Uniform Grant Guidance
  • Uniform Guidance Crosswalk from Existing Guidance to Final Guidance (http://www.whitehouse.gov/sites/default/files/omb/fedreg/2013/uniform-guidance-crosswalk-from-predominate-source-in-existing-guidance.pdf)
  • Uniform Guidance Crosswalk from Final Guidance to Existing Guidance (http://www.whitehouse.gov/sites/default/files/omb/fedreg/2013/uniform-guidance-crosswalk-to-predominate-source-existing-guidance.pdf)
  • Cost Principles Comparison Chart -- 2 CFR Part 225 (A-87), 2 CFR Part 220 (A-21), 2 CFR Part 230 (A-122), and Final Uniform Guidance (http://www.whitehouse.gov/sites/default/files/omb/fedreg/2013/uniform-guidance-cost-principles-requirements-text-comparison.pdf)
  • Audit Requirements Comparison Chart -- OMB Circular A-133 and Proposed Uniform Guidance Subpart F (http://www.whitehouse.gov/sites/default/files/omb/fedreg/2013/uniform-guidance-audit-requirements-text-comparison.pdf)
  • Definitions Comparison Chart (http://www.whitehouse.gov/sites/default/files/omb/fedreg/2013/uniform-guidance-definitions-text-comparison.pdf)
  • Administrative Requirements Comparison Chart (http://www.whitehouse.gov/sites/default/files/omb/fedreg/2013/uniform_guidance_administrative_requirements_text_comparison.pdf)

Other Uniform Guidance Resources

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