Office of Research

Federal Uniform Guidance

On December 26, 2014, the White House Office of Management & Budget (OMB) released new federal regulations: "Uniform Administrative Requirements, Cost Principles, & Audit Requirements for Federal Awards."

The new federal regulations supersede the requirements of previous OMB circulars, including:

  • OMB Circular A-21: Cost Principles for Educational Institutions
  • OMB Circular A-110: Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, & Other Non-Profit Organizations

Key Resources

When does the new federal guidance become effective?

December 26, 2014

How can I determine whether the new guidance applies to my award funding?

Old Guidance Applies to:

  • Awards, Renewed Awards, Supplements
  • Dated Prior to December 26, 2014

New Guidance Applies to:

  • Awards, Renewed Awards, Supplements
  • Dated on or After to December 26, 2014

*Note that supplements received on or after 12/26/2014 will be treated as under Uniform Guidance unless otherwise stated in the award terms and conditions or sponsor policy.

Timeline

April-June 2014 Discovery
June 26, 2014 Individual federal agency implementation plans released
September 30, 2014 Draft of Changes to UW policy
December 1, 2014 UW ready to implement changes
December 26, 2014 Guidance Effective for new funding received on or after December 26, 2014
June 30, 2015 End of the first UW fiscal year under the new guidance (audit requirements and negotiated F&A rates in place)
July 1, 2015 Beginning of first UW fiscal year under the new guidance
July 1, 2016 Changes to procurement provisions go into effect. (Note: this date represents a one-year extension of the original implementation date.)

UW Guidance Documentation and Communication

Unit Message Date Message/Resource
Multi-Unit 5/12/15 UG Agency Implementation Cheat Sheet 5.12.15
Multi-Unit 4/30/15 PI Quick Guide to New Federal Regulations
Multi-Unit 4/17/15 Guide to the CFR
Multi-Unit 3/30/15 UG Application Matrix 3.30.15
Grant and Contract Accounting 3/17/15 UW Federal Regulation Application Guidance 3.17.15
Office of Sponsored Programs 1/7/15 Prior Approval Reqs for Federal Awards 1.7.15
Office of Sponsored Programs 1/7/15 PI & Admin Quick Guide to New Federal Regulations 1.7.15
Office of Sponsored Programs 9/19/14 Proposal Preparation Guidance - Costing Policy Considerations in Light of Uniform Guidance
Office of Sponsored Programs 8/5/14 NW Chapter of Internal Auditors 8-5-14 TM
Office of Sponsored Programs 2/13/14 Omni-Circular UW Work Group Slides for MRAM

OMB and Federal Agency Guidance and Communication

Unit Message Date Message/Resource
Office of Management and Budget 3/12/15 UG Agency Implementation Cheat Sheet
Office of Management and Budget 3/11/15 Flow of Information on the Code of Federal Regulations
Office of Management and Budget 1/21/15 Federal Uniform Guidance
Council on Financial Assistance Reform 12/22/14 What Principal Investigators & Administrators Need to Know
Office of Management and Budget 12/19/14 Federal Uniform Guidance Federal Register
Council on Financial Assistance Reform 8/29/14 FAQs COFAR, August 29, 2014
National Science Foundation 5/29/14 US Federal Register, Volume 79, Number 90, May 9, 2014
National Science Foundation 5/29/14 National Science Foundation Proposal and Award Policies and Procedures Guide
National Science Foundation 5/29/14 NSF Notice on UG Implementation
Office of Management and Budget 2/14/14 OmniCircular –Senate Research Committee
Council on Financial Assistance Reform 2/12/14 COFAR Releases Frequently Asked Questions
cofar@omb.eop.gov
Council on Financial Assistance Reform 1/29/14 COFAR – COGR Review: OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
Council on Financial Assistance Reform N/A COFAR webpage with new Omni-circular and more
National Institutes of Health N/A NIH Commons Working Group

External Guidance and Communication

Unit Message Date Message/Resource
Council On Governmental Relations 1/14/14 Preliminary Assessment of Selected Items – OMB Uniform administrative Requirements, Cost Principles, and Administrative Requirements for Federal Awards
National Academies N/A All FDP presentations

The Omni Guidance Core Team

The Omni Guidance Core Team was assembled to:

  • Discover differences between past and new federal requirements
  • Identify changes and impacts to policies, procedures and systems and inform responsible units
  • Deliver final document noting changes and documenting: decisions for actions, reviewers and contacts, and required changes to policies, procedures and/or systems

Team Sponsors

  • Mary Lidstrom
    Vice Provost for Research
  • Susan Camber
    Associate Vice President,
    Financial Management

Team Members

  • Ted Mordhorst – Facilitator
    (Financial Management)
  • Phoebe Ambrosia
    (Financial Management)
  • Mike Anthony
    (Financial Management)
  • Lynette Arias
    (Office of Research)
  • Kathy Bracy
    (UW Medicine)
  • Czarina Francisco
    (Department of Medicine)
  • Linda Gamman
    (Office of Research)
  • Joe Giffels
    (Office of Research)
  • Ted Hanson
    (Department of Microbiology)
  • Carla Helm
    (Procurement Services)
  • Craig Johnson
    (Department of Medicine)
  • Gary Pedersen
    (Department of Chemistry)
  • Carol Rhodes
    (Office of Research)
  • Tami Sadusky
    (Financial Management)
  • Zenaida Shattuck
    (Internal Audit)

Contact: Ted Mordhorst, Assistant Director for Post Award Compliance, Research Accounting and Analysis