A UG would clearly be integral to the team, so long as the extent of the work was sufficient to require support on a relatively long-term basis at a substantial level of commitment (say .50 FTE or greater). However, an additional individual that was handling the normal work within the departmental office to support the same project would not qualify as a UG.
It is appropriate to purchase new computers only when necessary. If a project supports three new positions for a post-doctoral fellow and two graduate students and their was previously only had one graduate student in the lab, it probably wouldn’t be appropriate to purchase three computers for these employees. It might be, but if there is a relatively new computer that was used by a former graduate student (such that one of the students would have access to appropriate computing capability without purchasing a new device) then purchasing only two new computers would be appropriate. Note that making a purchase of computers in the last two or three months of a project will come under close scrutiny by an agency unless clear justification is provided.
The UG allows clerical and administrative salaries to be charged as direct costs to federally funded projects under limited circumstances. For charges to be allowed as direct costs, they must be:
- Associated with clerical and administrative personnel that are “integral” to the project, and
- That can be specifically identified with the project.
- The costs must be included in the project budget, or pre-approved by the agency as direct costs.
- The costs cannot also be collected as indirect costs.
Whether clerical and administrative personnel will be included in the budget will be assessed by SPO. In general, inclusion as a direct cost for administrative personnel will require that the level of effort required is clearly beyond that normally provided for a project. Parameters that might be considered could include the percentage of effort dedicated to the project, the length of time the position will be needed, the role of the individual in the project team, and the potential impact on the team if the position were not filled.
If a project involves several investigators on an international team and the amount of interaction required among the team is high, a person with specific knowledge of the international regulatory environment, or that has experience with facilitating communications among individuals with diverse languages and backgrounds would clearly be integral to the team, so long as the extent of the work was sufficient to require support on a relatively long-term basis at a substantial level of commitment (say .50 FTE or greater), may be included in the direct costs for the project. However, an additional individual that was handling the normal work within the departmental office to support the same project would not qualify.
The Office of Management and Budget (OMB) has provided a one-year grace period for implementation of the new procurement standards. They will become effective at USU as of July 1, 2016. Until then, USU will continue to follow standards in OMB Circular A-110.
- Micropurchases will be allowed up to $3,000.
- Small purchases are allowed up the “Simplified Acquisition Threshold” of $150,000. Price or rate quotations are required from an adequate number of qualified sources.
- Sealed bids will be used to obtain firm fixed-price contracts where appropriate.
- Competitive proposals will be used to obtain services that are not appropriate for procurement by sealed bids.
- Non-competitive proposal, or sole-source purchases are allowed. The requirements for use of non-competitive procurement are allowed when one or more of the following is true:
- The item is available only from a single source;
- The need for the purchase is tied to an emergent public need, and delay of the purchase would cause an unwarranted delay;
- The funding agency authorizes a non-competitive proposal process based on a written request from USU; or
- After solicitation of a number of sources, the competition is determined inadequate.
The UG sets a standard for funding opportunities to be available to the public for 60 days. Federal agencies may receive exceptions from this requirement from the OMB, but no notification can be available for less than 30 days under the new regulations.
The UG requires that any cost-sharing requirements related to a funding opportunity be included in a funding opportunity notification. If cost-sharing is required in the funding announcement, the university’s cost-sharing plan must be reflected in the budget. As always, all cost-sharing must be allowable under the UG’s cost principles and must be allocable to the project.
In general, cost sharing will not be permitted if it is not mandatory. However, in cases where key personnel on the project do not include any of their own effort in the budget, the UG includes a reference to the OMB Memorandum that requires that some effort be imputed to the project. USU will continue this required practice.
Subrecipient monitoring has been a hot topic for agency auditors for several years. The UG requires a risk assessment be performed for all subrecipients. This function will be performed by the Sponsored Programs Office (SPO), and will require the collection and analysis of additional information. SPO will lead USU’s efforts under this requirement, in collaboration with the PI and the subrecipient.
PIs and project staff are in the best position to monitor the subrecipient’s performance of technical requirements and adhering to project budgets. SPO will query PIs throughout the life of a project to identify any areas of concern that may arise.
The UG guidance on closeouts is the same as OMB’s previous requirement that project documentation for closeout be submitted within 90 days of the end date of the period of performance.
Some new conditions affect closeout at the agency level, some agencies are now tracking project activity in separate subaccounts, rather than in aggregate under a letter of credit or similar arrangement. Agencies are now in a position to identify when activities are extending beyond the end date, and if documentation is not received on a timely basis, they may withhold future payments not only for the project, but for all agency funded projects.
To ensure timely closeouts the Sponsored Programs Office (SPO) and Sponsored Programs Accounting will be seeking subrecipient closeout documentation within 45 days of the end date of each project. PIs should be aware of these requirements, start the closeout process early and provide for this 45-day deadline within their project schedules.
The UG requires that all federal agencies recognize an institution’s negotiated F&A rate. Federal agencies that have a statutory cap on F&A rates associated with federally funded grants and contracts will be able to continue to enforce those caps; however, agencies will no longer be able to arbitrarily set rate caps that do not allow USU to recover F&A at its negotiated rate. All deviations in payment of established F&A rates must be approved by OMB. USU will leverage this guidance with federal agencies and with state pass-through entities to capture more of its indirect costs by charging its full F&A rate.
The UG requires that subawardees under federal awards be paid overhead costs at their negotiated F&A rate (unless the agency has a statutorily reduced F&A cap). If the subrecipient does not have an establish rate USU will pay at a rate of 10% of Modified Total Direct Costs (MTDC), as allowed in the UG.