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This document summarizes the key points discussed during the Financial Representative Meeting on February 17, 2014, regarding OMB's Uniform Guidance, also referred to as the "Super Circular." It highlights its objectives to streamline requirements and focus on effectiveness, consolidating eight OMB Circulars. The final guidance was issued on December 19, 2013, with audit requirements effective from fiscal years after December 26, 2014. It also outlines updates on the National Science Foundation's Proposal and Award Policy changes, effective February 24, 2014.
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Financial Rep Meeting February 17, 2014
Sponsored research administrationroberta mcmanusjulie wammack
OMB Uniform Guidance • AKA “Super Circular” • Council on Financial Assistance Reform (COFAR) • Agency CFOs eventually took over effort • Council on Governmental Relations (COGR) partner • 2 year process – commenced 2012 • Initial comments submitted April 2012 • Proposed guidance issued February 2013 • Comments submitted in May 2013 • Final guidance issued December 19, 2013 • Objectives • Streamline requirements • Focus on effectiveness • Combines 8 OMB Circulars, for FSU: • A-21 Cost Principles • A-110 Administrative Requirements • A-133 Audit Requirements
Super Circular Effective Date • December 26, 2014 • Applies to new awards and incremental funds awarded after December 26, 2014 • Audit requirements effective for fiscal years commencing after December 26, 2014 • For FSU = FY 2016
Super Circular Structure • Part A – Acronyms and Definitions • Part B – General Provisions • Part C – Pre-Federal Award Requirements • Formerly A-110 Subpart B • Part D – Post Federal Award Requirements • Formerly A-110 Subpart C • Part E – Cost Principles • Formerly A-21 • Part F – Audit Requirements • Formerly A-133
SRA Management Team Plan • Review Super Circular Guidance • Jan – Mar 2014 • Council on Governmental Relations (COGR) assessments • COFAR trainings • Compare guidance to and update SR Policies/Procedures as appropriate • Mar – Sep 2014 • Notice to campus • General communications • Mar – Dec 2014 • Guidance for proposal submissions • May – Jun 2013 • Training • CReATE • SRA Certificate Series updated with new information • Timing: Oct – Dec 2014
Resources • Council on Financial Assistance Reform (COFAR) • https://cfo.gov/cofar/ • Link to Super Circular • Crosswalks – Old to New • January 27, 2014 training • Videos • Power Points • Mailing list • FAQs (future posting) • SRA Listserv • Sign up to ensure you receive communications • Subscribe at: http://www.research.fsu.edu/contractsgrants/listserv.html
National Science Foundation Proposal and Awards Policy & Procedure Guide (NSF P&P) Updates
NSF P&P Changes • NSF website at http://www.nsf.gov/pubs/policydocs/pappguide/nsf14001/nsf14_1.pdf • Effective February 24, 2014 • Part I - Grant Proposal Guide (GPG) • Part II – Award & Administration Guide (AAG)
NSF Changes - GPG • Submission requirements • FastLane • Grants.gov • SAM – System for Award Management • Replaces Central Contractor Registration (CCR) • NSF system of record for organizational financial information effective October 1, 2014 • PI will select collaborative or not and the type of proposal • Certifications: • Additional info regarding conflict of interest – must be disclosed through Notifications & Requests Module in FastLane • Provides a list of required sections for a full proposal to be submitted via FastLane
NSF Changes - GPG • Project Summary • If special characters are used then submit a pdf that has headings for overview, intellectual merit, and broader impacts • Results from Prior NSF Support • Must include intellectual merit and broader impacts in separate sections • PI or Co-PI need only include in this section one award previously received that most closely related to the proposal • Unfunded Collaborations • Individuals not included in the budget • Describe in the Facilities, Equipment and Other Resources section • Biographical Sketches • Include more than specification – returned without review!
NSF Changes - GPG • Budget Development • Participant support costs – No F&A • Guidance on allowability of visa costs • Short-term visa costs MAY be allowable • Conferences, Symposia, Workshops • Need to plan for child care and other types of family care at the conference site to allow individuals with family care responsibilities to attend
NSF Changes - GPG • Guidance for long-term absence of the PI/Co-PI when working for NSF as • Intergovernmental Personnel Act Employee (IPA) • Visiting Scientist, Engineer or Educator (VSEE) • Annual and Final Reports • Reports are not cumulative – most recent budget period • Submit via Research.gov • Award Cash Management Service (ACM$) • Acknowledges implementation of ACM$ • Federal Financial Reporting no longer required • Awardees must certify that all disbursements have been made or will be made within 3 days of receipt when requesting payment • Financially closed three months after award expiration • Final expenditures pulled from ACM$ • If changes by $1 or more – adjustment to Financially Closed Award must be submitted • Based on final payment amounts the final unobligated amount will be deobligated from award amount
NSF Changes - GPG • Post-Expiration Costs • Costs incurred on or before expiration date allowable • Purchases at the end of the award not allowable • Must be able to demonstrate benefit to the award scope – expect more questions! • Allowability of Costs • Participant Support costs may include fellowships, scholarships, other forms of student aid • Rental costs of facilities owned by the awardee limited to actual cost of ownership • Awardee’s ultimate responsibility to ensure that all project costs meet all requirements (cost principles, award document, terms & conditions, etc.) • Consultant costs should be fully disclosed and explained in budget justification • Relocation costs that were not included in the proposal budget, must be fully documents in accordance with awardee’s policies and procedures • Visa costs allowable when short-term and individual essential for project • Environmental Compliance • Prior to making the award, NSF may ask for environmental impacts from project • If environmental event occurs or comes to light during project – • Stop work and notify NSF