Uniform Guidance, What to Expect: October 2014

What will the Emory Working Groups for Uniform Guidance focus on over the next couple months?

The Emory Working Groups who were discussed in the September Emory Research Administration Newsletter are preparing for the implementation of Uniform Guidance at Emory and have begun their regular meetings.  These groups will evaluate the impact of the Guidance on Emory policies and procedures.   Following this evaluation, policy revisions will be drafted in preparation for the implementation. In addition, current educational documents, and manuals which represent OMB Circulars A21, A110 and A133 will need to be updated.

It is not anticipated that anything will be finalized until we receive the actual guidance from NIH and the other federal agencies. Issuance of the finalized guidance is anticipated by 12/26/14.  Upon receipt of the guidance from federal agencies, the Working Groups will issue all resulting changes to the Emory research community in early 2015 (calendar year).   As noted, the structure includes a Working Group that will focus on Communication and Education.  This group will evaluate how to best communicate the changes to Emory’s research community and provide any necessary education.

Further information regarding the Working Groups and the timeline can be accessed at:  http://www.ogca.emory.edu/ugep/implementation.html.

What needs to be thought about as proposals are being prepared (during the period prior to the agencies providing their new guidance)?

While the full impact on proposal preparation going forward is still to be determined (as agencies issue their guidance), it is recommended that as proposals are prepared, the new Guidance is kept in mind.   For example, an anticipated change is the ability to direct charge administrative salaries.  Any administrative salaries planned to be direct charged to the award need to be integral to the project and are expected to require prior approval.  Because of this, if you do plan to charge administrative salaries on a project for which you are submitting a proposal, the proposal should include the proposed cost within the budget and justification within the budget narrative.  Similarly changes are anticipated that allow direct charges for technology.  It is recommended that the proposal budget and budget narrative include any technology that is required for the project and is expected to be charged to the project.  To date, NIH has not provided any official guidance regarding how these areas will be handled for modular budgets.  To this point, it is recommended that you address these issues within your modular award narrative as much as feasible.

As the agencies issue their official guidance, we will provide further direction on any proposal recommendations.  For a quick video discussion related to these topics, please see “The New Guidance Considerations – NCURA” available at http://www.ogca.emory.edu/ugep/learning.html.  If you have any questions regarding the proper preparation of a proposal, please contact your RAS or OSP representative.

Who can I contact regarding questions related to the new Uniform Guidance?

Questions can be directed to members of the Emory Working Groups, OSP, and OGCA or directly to Kerry Peluso at kpeluso@emory.edu.






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