If you came here looking for ways to get your hands on some delicious mini-burgers, this post is not for you.
If, however, you’re looking for a way to simplify unallowable cost determination under the Super Circular, rejoice! Cost-allocation software company CostTree is giving away handy pocket sliders to aid you in your cost determination quests (and if you’re not into print materials, they have a digital version, too).
To get yours, head on over to the CostTree request site and input your vitals. It’s helpful, it’s nice-looking, and it’s free for the low, low cost of being added to a mailing list. Happy allocating!
Greetings, research community! As a follow-up to our Wednesday post, we’d like to draw your attention to a new resource on our homepage: Uniform Guidance Changes for 2015. In this document, we’ve highlighted the major changes and how they might affect your proposals going forward. Let us know if you have questions!
The NIH announced on February 5, 2015 their guide to NIH-specific implementation of the Office of Management and Budget (OMB)’s Uniform Guidelines (UG), in place since December 26, 2014. The NIH Interim Grant General Conditions apply to all new and supplemental funding provided by Notices of Award issued on or after December 26, 2014; they contain no surprises if you’ve been keeping up with the road to implementation! If you need a refresher on how we got here, take a look at some of our older posts, like Super Circular, Super Fun, which highlights some of the new provisions in the UG; and Ch-Ch-Changes, which also has a link to the NIH Administration Timeline.
To comb over the NIH Interim Guidelines yourself, the full document can be accessed here. These will be in effect until an updated NIH Grants Policy Statement is published (which won’t be until after the HHS comment period closes). NIH has provided a frequently asked questions page regarding the interim guidelines, on which you may be able to find an answer to any general questions you may have. If your question is more specific than an FAQ page can handle, give us a try! We’re always happy to help with interpretation and applicability!
Looking for some information on what, exactly, has changed? Check out our handy Uniform Guidance Changes: 2015 page!
As we draw nearer to the implementation of the Super Circular, our friends at NCURA continue to put out some very helpful vlogs (video logs) on some of the highlighted changes. There is a new rule for indirect cost rate negotiations, in fact, that now allows a one-time, four-year extension on current negotiated rates. This is governed by section 200.414 (linked, for your reading pleasure); you can check out the short NCURA video here:
The possibility of a rate extension theoretically saves universities (and other entities) time and negotiation resources by allowing for the postponement of the process. Of course, the costs associated with the preparation of the proposal for the extension itself are other other consideration factors. What is your opinion on the effect of this change; will it save administrative burden as intended? We’d love to hear your thoughts!
When utilizing subcontracts on a proposal, occasionally we run into domestic institutions who have no negotiated federal rate agreement. This means (among other things) that there is no F&A rate. If the subcontracting institution doesn’t require administrative overhead in their role on the project, it’s not necessary to grant them these costs. But what if they do require administrative costs? Scientists gotta science, administrators gotta administer!
For cases like these, there is a minimal threshold set by the federal government for institutions with no negotiated rate: it has been 8%, but has been increased by the OMB Uniform Guidance to 10% for domestic institutions, effective December 26, 2014 (as stated in Section 200.110). We have been successful here at using the 10% rate on proposals as of late. To view the full text of the Final OMB Uniform Guidance regarding the increase of the de minimis threshold, take a look at Subpart E, 200.414 on the Federal Register site. For a breakdown interpretation of the language (for this and other changes), check out the table produced by The Huron Consulting Group, or our post entitled “Super Circular, Super Fun“!
RAS is here to help if you have any questions on how to budget your subcontracts with no negotiated rate. Feel free to reach out if you need us!
It’s been around for nearly six months now, but the OMB Super Circular (also known as the “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Final Rule”, and “Mega Circular”) is receiving some more attention as opportunities for its application increase. Many of you who attended the most recent SPA meeting most likely received a copy of the Huron Group’s chart, “Assessing the OMB Uniform Guidance: Major Changes and Impacts.” If you did not, it is available here and offers helpful visual reference as to how your strategies may change. Some of the highlights include:
Length of Opportunity: The guidance indicates that RFAs and PAs have to be available 60 days before the opportunity closes.
Accountability – Performance vs. Compliance: Results and outcomes that can be shared with other award recipients have strong emphasis in the new guidance. Noncompliance is not merely overlooked, of course; but the government ostensibly does not wish to create oppressive rules that prevent an investigator or a collaborating team from attaining their research aims. As you read the guidance, you’ll see that this is the goal.
Administrative Costs as Direct Costs: Specific information is given on how to manage administrative costs as a direct cost. Administrative costs are usually charged as indirects, so this can be tricky. If you’re unsure on how to do this, please contact RAS and we’ll help you figure out how you should be charging your admin costs.
Increasing Minimal Threshold for Indirect Costs to 10%: Organizations that cannot afford to negotiate an indirect rate can budget a 10% de minimis indirect rate with the federal government (as opposed to the previous rate of 8%).
Payment Management : The super circular provides new information on maintaining consistency in cost allocation, and at what point you need written approval for assigning a cost to an award. The cost principles and audit sections assert that there is now a limit of three years for the federal government to review awards in order to disallow costs. There is also a new 90 day rule for reporting on awards at the end of the project period. Taken together, there is much latent encouragement to spend your money before it is taken back.
Family-Friendly Policies: The new guidance encourages federally-funded organizations to implement family-friendly policies, including family-friendly issues such as costs related to the identification of day-care providers, and allowance of parents to document out-of-workforce time on biosketches.