1 / 24

Recent Changes Published in Part 200 Uniform Guidance -- Cost Principles Steve Bradley,

Recent Changes Published in Part 200 Uniform Guidance -- Cost Principles Steve Bradley, Director. Agenda. New Structure (“Roadmap”) Highlighting relevant F&A and Cost Principle sections Costing Principles Including eliminations of prior A-21 sections MAXIMUS Impact Assessment

decima
Télécharger la présentation

Recent Changes Published in Part 200 Uniform Guidance -- Cost Principles Steve Bradley,

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript


  1. Recent Changes Published in Part 200 Uniform Guidance -- Cost Principles Steve Bradley, Director

  2. Agenda • New Structure (“Roadmap”) • Highlighting relevant F&A and Cost Principle sections • Costing Principles • Including eliminations of prior A-21 sections • MAXIMUS Impact Assessment • Resources

  3. Structure (cont.) • Subpart E– Cost Principles (A-21, A-87, A-122)

  4. Structure (cont.) • Subpart F – Audit Requirements (A-133) • Appendices (combination of all 8 Circulars) • I – Notices of Funding • II – Contract Provisions • III -- F&A for Educational Institutions (A-21) • IV – Indirect for Non-Profits (A-122) • V – State/Local Cost Allocation Plans (A-87) • VI – Public Assistance (A-87) • VII – State/Local Indirect Cost Plans (A-87) • VIII – Non-Profit Exemption from Cost Principles (A-21) • IX – Hospitals (TBD) • X – Audit Data Collection (A-133) • XI – Single Audit Compliance Supplement (A-133)

  5. OMB Changes – Combine Circulars • Consolidate A-87, A-21 and A-122 Cost Principles • Create a common accounting standards for all grant recipients • IMPACT • --Probably add more confusion than clarity • --Universities are much different than Non-profits and State/Local Govt’s • --Document littered with “exceptions” (e.g., A-21 26% Admin cap )

  6. OMB Changes – Flat Rate • For F&A costs, use a flat rate instead of current negotiated rate system – NOT in new guidance • IMPACT • GREAT! • Flat / “tiered” rate idea was not well received and has been dropped

  7. OMB Changes – UCA (App. III B.4.c) • Maximum 1.3 Utility Cost Adjustmentwith “Utilities” allocations based on “Effective square footage” • ESF is actual SF times “Relative Energy Utilization Index (REUI) • REUI is currently 2X • OMB will adjust factor “no more often than annually nor less often than every 5 years” • Allows metering at a Sub-Building level???? • IMPACT • GREAT (for some)! • Increase burden (for others)! • Perhaps aDouble-Edged Sword? • Schools will now have to develop data for their Utilities pools • “Separate Proposal”

  8. OMB Changes – Eliminate Required Study • Eliminaterequirement for institutions to conduct studies for cost reasonableness for Large Research Facilities • prior A-21, F2 • IMPACT • --GREAT! • --Reduce administrative burden

  9. OMB Changes – Eliminate Mandated F&A Usage • Eliminaterequirement that certain institutions must use F&A recoveries associated with depreciation to acquire or renovate research buildings or equipment • prior A-21, J14h • Currently applies to 99 schools • IMPACT • --GREAT! • --Reduce administrative burden

  10. OMB Changes – Eliminate Required Analysis • Eliminate requirement that schools perform a Lease Purchase Analysis to justify External Bond Interest • prior A-21, J26 • now Subpart E, 200.449 • IMPACT • --GREAT! • --Reduce administrative burden • --But, Retained “25% Equity Contribution” rule

  11. OMB Changes – DS-2 (Subpart E, 200.419) • Disclosure Statements (DS-2) & Compliance under the Cost Accounting Standards Board (CASB), retained(prior A-21, C14) • Threshold raised from $25M to $50M • Added: University proposed change must be submitted to DCA/ONR 6 months in advance • IMPACT • --Reduce administrative burden? • Change in effect next FY unless hear from DCA/ONR

  12. OMB Changes – 10% Rate for First-timers • Addition of 10% de-minimus indirect cost rate (modified total direct cost basis) for entities that do not currently have a negotiated rate • Subpart E, 200.414 • IMPACT • GREAT! • --May reduce the need for university staff to review indirect proposals from these type sub awardees / subcontractors

  13. OMB Changes – Cost Sharing • Affirm that Voluntary Committed Cost Sharingis NOT expected & is NOT to be used as a factor in review of applications • Subpart D, 200.306 • Onlymandatory cost sharing and cost sharing specifically committedin the projectbudgetmust be included in the organized research base • IMPACT • GREAT! • --Probably reduce administrative burden and/or Organized Research “base” • --VUCS clarification still in effect

  14. OMB Changes – Direct Charging of Admin. • Salaries of administrative staff may be direct chargedto federal grants where ALL of the following are met: • Services are integral to the project • Individuals can be specifically identified to the project • Explicitly included in the budget or have prior written approval • AND, are not recovered as indirect costs • Subchapter E, 200.413 • IMPACT • DOUBLE-EDGED SWORD! • --May reduce confusion • --But may increase the Organized Research MTDC baseand, in turn, lower proposed rates • --As offset, F&A rates would be applied to these new direct costs, increasing F&A Dollar Recoveries

  15. OMB Changes – Rate for All Agencies • Require Federal agencies to accept negotiated indirect (F&A) cost rates, unless an exception is required by statute or regulation; and, Federal agency must notify OMB of any approved deviations • Subpart E, 200.414 • IMPACT • Regrettably, not much change • Except, OMB will now have central repository of these • For example, USDA, 8% Training grants, etc., will probably stay at reduced F&A rates

  16. OMB Changes – Effort Certification • Remove the “Examplesof Acceptable Methods for Effort Certificationfor Payroll Distribution” • Emphasis on “InternalControls” and “Performance” • prior A-21, section J10 • Subpart E, 200.430 • IMPACT • Reduces Effort Certificationburden • Allows “flexibility in how universities can meet standards” • “Final guidance does not require current PAR’s/similar documentation” • Also, FDP doing their own “Project Certification” Demo, including reviews by OIG’s

  17. OMB Changes – Rate Extension • All Non-Federal entities may apply for a one-time extension of current F&A rates for up to four years, subject to cognizant agency approval • Subpart E, 200.414 • IMPACT • May be appropriate for some universities • For others, may reduce F&Adollar Recoveries (e.g., if major new research buildings, if now eligible for UCA, or substantial decrease in base re: end of ARRA grants)

  18. OMB Changes – Computing Devices • Addition of new language which allows “Computingdevices” and associated support costs to be treated as allowable and allocable direct costs • Subpart E, 200.453 • IMPACT • DOUBLE-EDGED SWORD! • May reduce confusion • But may increase the Organized Research MTDC base and, in turn, lower proposed rates • As offset, F&A rates would be applied to these new direct costs, increasing F&A Dollar Recoveries

  19. OMB Changes – MTDC (App. III C.2) • App. III C.2. references section 200.68 where participant support costs, defined in 200.75, are listed as an exclusion to MTDC • Other items may only be excludedwhen necessary to avoid a serious inequity in distribution of indirect costs, and with the approval of the cognizant agency • IMPACT • -- Perhaps increase burden to identify new exclusion • -- Possibly deter agencies adding unfair base exclusions (e.g. genomic arrays)

  20. OMB Changes – Library Expenses (App. III B.8) • The professional employee category can include post-doctorate fellows and graduate students • The other users category can be based on a reasonable factor as determined by institutional records to account for all other users of library facilities • IMPACT • --GREAT! • --Support standard practice allocation to postdocs and grad students • --Reduce administrative burden

  21. OMB Changes – Dual Role of Students • Kept language stating“ … the dual role of students as both trainees and employees contributing to the completion of Federal awards for research must be recognized in the application of these principles.” • Subpart E, 200.400(f) • IMPACT • --GREAT! • --May have reduced F&A rates if omitted

  22. Unresolved Issues • When will revised DCA Best Practices Manualbe published? • UCA for FY14 base year F&A rate proposals? • Definition of “monitored research laboratory space” re: UCA • Format for “separate calculation proposal” for UCA • Does “one time” extension mean once in the life of the rate or once in the life of the institution • Send questions to COFAR cofar@omb.eop.gov

  23. Resources • http://www.maximus.com/our-services/education/higher-education/omb-uniform-guidance • Federal Register article: Web | PDF • 2 CFR Part 200: eCFR - Code of Federal Regulations • The OMB website includes many helpful links: • OMB Policy Statements: Uniform Grant Guidance • Crosswalkfrom Existing Guidance to Final Guidance • Crosswalkfrom Final Guidance to Existing Guidance • Cost Principles ComparisonChart • Audit Requirements Comparison Chart • Definitions ComparisonChart • Administrative Requirements ComparisonChart • COFAR

  24. Contact Us • Email: highereducationinfo@maximus.com • Telephone: 800-709-2747 • Website: http://HigherEducation.MAXIMUS.com • Facebook: MaximusHEP • Twitter: #MaximusHigherEd

More Related