Who needs to know about Uniform Guidance?
Anyone who is involved in federal research at Emory University and/or the administration of those activities is responsible to know and understand the changes that Uniform Guidance brings. Reading Emory’s monthly Research Administration Newsletter will ensure that you are aware of the information that you need to know.
What is Uniform Guidance?
The Office of Management and Budget (OMB) is the federal agency that is responsible for leading the development of government-wide policy to assure that grants are managed properly and that Federal dollars are spent in accordance with applicable laws and regulations. They are the agency that was responsible for issuing (and maintaining/updating) the A21, A110, and A133 OMB circulars. These have been the umbrella policies that Emory and other research universities (who have accepted federal funding) have been required to remain in compliance with. A21 provided the “Cost Principles for Educational Institutions”, A110 provided “Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations”, and A133 provided guidance on “Audits of States, Local Governments, and Non-Profit Organizations. These have all been very important documents for Emory in our administration of federal research. In an effort towards streamlining administrative efforts, OMB has led the effort of combining these three circulars with five other circulars into one new document called “Uniform Guidance”. Beyond consolidation of the eight documents into one, the other stated goals were to update the outdated requirements in the former circulars and to update requirements in a manner would reduce some of the administrative burdens created by the former circulars.
To handle the task of meeting these objectives, an interagency group was formed. This group is called the Council on Financial Assistance Reform (COFAR) and they were delegated the responsibility for to lead the development of Uniform Guidance. It is important to note that many other groups are covered by Uniform Guidance including state organizations. While research universities receive a high percentage of total federal awards to be issued under Uniform Guidance, we are a very small percentage of the total funding that will be issued under this guidance. This guidance document had to meet the needs of a large variety of different funding types and organizations.
On 12/26/13, OMB issued Uniform Guidance stating that it would become effective on 12/26/14. This new circular is issued as guidance to federal grant making agencies. It provides the requirements that these agencies need to develop and issue their federal guidelines within. To date, only NSF has provided their draft implementation plans for comment. We have been informed that we will receive the new guidelines and implementation requirements from other federal agencies by 12/26/14 (on the date they are stated to become effective). We are unsure whether these will be issued in draft form, whether we will have a comment period, or what the roll out process will be for each federal agency. We may not have any of this information (except for NSF) until 12/26/14.
Following the publishing of Uniform Guidance on 12/26/13, research universities had many questions. While some changes are very positive, including the updating of the circulars to address the modern needs for computing devices and electronic documentation, other changes were not clear and did not seem to properly represent the needs of research universities. In a collaborative effort between COGR (Council on Governmental Relations), FDP (Federal Demonstration Partnership), and representatives from several research universities (including Emory), regular meetings have been held to discuss and clarify the concerns and questions coming from research universities. On 8/29/14, COFAR issued a list of FAQ’s which addressed some of these concerns and questions (but not all). Further discussions continue regarding outstanding issues and concerns.
What is Emory doing to prepare?
While the overall broad impact of this guidance is not anticipated to be enormous, there will be significant impacts for some areas. These changes create the need for us to revise some University policies and procedures. Some regulations have been relaxed and will provide us with greater flexibility on how we set policy. There are also some areas that will require some additional thought at the proposal stage to ensure that we fully benefit from the changes. In order to ensure that we are (1) restructuring our guidance, policies, and procedures in the manner that will most benefit Emory’s researchers, (2) that we are taking full advantage of any flexibility offered by the Guidance, and (3) that our research community is aware of these changes, we have formed a committee structure and eight working groups to handle these responsibilities. The members of this initiative are as follows:
Uniform Guidance, Emory Planning (UGEP) – Steering Committee
- Kerry Peluso, OSP/OGCA (Chair)
- Patricia Bauer, Emory College
- Kathleen Bienkowski, Research Administration Services (RAS)
- Diana Carter, Division of Finance
- Sharen Olson, School of Medicine
- Scott Stevenson, Internal Audit
- Dean Surbey, School of Public Health
- Martha Walsh, Yerkes
Uniform Guidance, Emory Planning (UGEP) – Working Groups
- UGEP- Procurement
- UGEP – Post Award (includes Direct Costs, Closeouts, etc.)
- UGEP – Costing (includes DS2, Fringe Benefits, F&A, etc.)
- UGEP – PreAward (other than subrecipient monitoring)
- UGEP – Subawards and Subrecipient Monitoring
- UGEP – Effort Reporting
- UGEP – Equipment
- UGEP – Communication and Education
This structure will be responsible for the following:
- Identifying the current Emory University level policies, procedures and guidelines which will require modification as a result of the implementation of Uniform Guidance.
- Leading the process to determine the best way to modify the items in (1) that will allow Emory to benefit (as much as possible/allowable) from the changes.
- Modifying the documents identified in (1).
- Communicating the changes to the Emory Research Community.
**It is important to keep in mind that, while we would like to have the work above done prior the formal implementation date of 12/26/14, because agency implementation plans are not expected to be issued until that date, some of the work above will not be able to be finalized until after 12/26/14.
What do you need to do?
If you are involved in research or the administration of research at Emory, you need to read Emory’s monthly Research Administration Newsletter. This will ensure that you are aware of the changes resulting from Uniform Guidance and will have the information needed to prepare for and manage federal awards in this new world. While there will be various meetings held throughout the Emory campus over the upcoming months, we want to ensure that there is one easily accessible location where you can access the information that you need to know. The newsletter will be the main communication channel for this information and reading it will allow you to keep up to date on what you need to know.
Where can I obtain further information?
While we will ensure that you receive the information that you need within Emory’s monthly Research Administration Newsletter, we realize that some of you may wish to have more information or follow this topic more closely. A webpage has been set up to provide you with links to documents related to Uniform Guidance and access to other tools to learn more about Uniform Guidance. This information can be accessed at http://www.ogca.emory.edu/ugep/index.html. Both OGCA and OSP websites also have direct links to this webpage.
Questions and comments regarding Uniform Guidance should be directed to Kerry Peluso at kpeluso@emory.edu.
If you are not receiving monthly email links to our newsletters, information on how to subscribe can be obtained from http://www.osp.emory.edu/communications.html.
***Topics Coming in Emory’s October Research Administration Newsletter***
At Emory, what benefits and changes can we expect from Uniform Guidance?
What needs to be done during proposal preparation as we prepare for these changes?