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). However, an additional individual that was handling the normal work within the departmental office to support the same project would not qualify.
Yes, under appropriate conditions computing devices can be purchased as supplies and need not be listed separately in budgets. The conditions include that the device must be essential to and directly related to the project. It is not necessary for the device to be used exclusively on the project, however.
If the equipment meets the threshold for capital equipment at USU (over $5,000) it should be purchased under that budget line item. You should also consider whether the project would otherwise have reasonable access to other computers that could support the project. Finally, it is important that USU treats purchases of computers consistently from one project to another. Consult with your Sponsored Programs representative to make sure the project budget and justification is appropriately developed.
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 2 new computers would be appropriate. Note that making a purchase of computers in the last 2 or 3 months of a project will come under close scrutiny by an agency unless clear justification is provided.
The UG requires that for charges to be allowed as direct costs, they must be:

  1. associated with clerical and administrative personnel that are “integral” to the project, and
  2. That can be specifically identified with the project.
  3. The costs must be included in the project budget, or pre-approved by the agency as direct costs.
  4. The costs cannot also be collected as indirect costs.
The elements in the question above will be assesses by SPD. 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.
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). However, an additional individual that was handling the normal work within the departmental office to support the same project would not qualify.
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.
  1. Micropurchases will be allowed up to $3,000.
  2. Small purchases are allowed up the the “Simplified Acquisition Threshold” of $150,000. Price or rate quotations are required from an adequate number of qualified sources.
  3. Sealed bids will be used to obtain firm fixed-price contracts where appropriate.
  4. Competitive proposals will be used to obtain services that are not appropriate for procurement by sealed bids.
  5. Non-competitve proposal, or sole-source purchases are allowed. The requirements for use of non-competitve 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.
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.
Yes, 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.
The UG requires a risk assessment be performed for all subrecipients. This function will be performed by the Sponsored Programs Division (SPD), and will require the collection and analysis of additional information. SPD 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. SPD will query PIs throughout the life of a project to identify any areas of concern that may arise.
Yes. 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.
The Sponsored Programs Division 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.
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.