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OMB Final Uniform Guidance, effective December 26, 2014

 

On December 26, 2013, the Office of Management and Budget (OMB) published its comprehensive overhaul of federal grant administrative, cost accounting, and audit policies in the Federal Register, to be codified in the Title 2 of the Code of Federal Regulations. This final guidance, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. supersedes and combines the requirements of eight existing OMB Circulars (A-21, A-50, A-87, A-89, A-102, A-110, A-122, and A-133). The Uniform Guidance significantly reforms federal grant making to focus on improving performance and outcomes with the intent to reduce administrative burdens for grant applications and recipients and reduce the risk of waste, fraud, and abuse. 

The Uniform Guidance is effective December 26, 2014. New and incrementally-funded awards issued on or after December 26, 2014 will be subject to the Uniform Guidance. Audit Requirements will apply to audits of fiscal years beginning on or after December 26, 2014. For Clarkson, the Audit Requirements become effective for the fiscal year July 1, 2015-June 30, 2016. 

Some of the biggest and most far-reaching changes brought about by the Uniform Guidance are related to procurement. Compliance with these new requirements is currently under review and it may involve changes to research policies, University-wide procurement processes, and/or computer systems. Our goal in this effort to comply is to transform our processes and policies in an way that allows compliance while keeping our researchers focused on their research and keeping the University administrative burden as minimal as possible. The OMB has granted a grace period to allow extra time for a systematic implementation. Rather than full compliance by December 26, 2014, Clarkson must have a plan in place that ensures compliance with the Uniform Guidance procurement requirements no later than July 1, 2016.  More to follow.

A working group was established with representatives from the Division of Research, Controller's Office, Risk Management, OIT, and Human Resources to review the regulations and continue to stay up to date regarding ongoing issues and clarifications related to the UG.  The Division of Research will post updates and implementation plans as they become available.