As published in the Federal Register on February 1, 2013, the Office of Management and Budget (OMB) has issued proposed guidance on the reform of federal policies relating to grants and cooperative agreements, cost principles, and administrative requirements.  The higher education community has been given until June 2, 2013 to provide feedback to the proposed reforms.

At a high level, the proposal includes the combination of eight OMB Circulars into one document (relevant circulars for the university community include A-21, A-110, and A-133).  At a more detailed level, there are proposed clarifications and potential changes to areas such as sub-recipient monitoring, language on the dual role of students, alternatives to time and effort reporting, reimbursements for utility costs via the F&A rate, administrative support on grants, and computing devices on grants, amongst many others.

While many of the suggested changes have the potential to be positive for Emory, there are some that have the potential to cause additional administrative burden.  We will be evaluating each issue and will comment on the ones that we feel may create unnecessary burden or cause confusion.

The most important thing to note is that these reforms are proposed.  There is nothing final at this point and there likely will not be anything final for quite some time, as both OMB and the university community need to be given enough time to weigh all proposed items and responses accordingly.

If you have any questions regarding the information contained in the proposed reform, please contact Josh Rosenberg at josh.rosenberg@emory.edu or via phone at (404) 727-1677.