Consistent Uniform Guidance Interpretation Across Agencies

Princeton University submits that the Uniform Guidance benefits higher education institutions in many ways, but only so long as the federal awarding agencies interpret the rules of the Uniform Guidance consistently. The following captures a few areas where consistency is needed:

A. Sections 200.203(a)(5), Notice of funding opportunities (CFDA Numbers), and 200.301, Performance measurement – neither of these sections are being implemented consistently across the federal awarding agencies which causes grantees to spend more time trying to ensure that each federal awarding agency is satisfied with the grantee’s proposal and subsequent documentation.

B. Under section 200.306(a), Cost sharing or matching, some federal agencies are not being explicit, but rather vague by “encouraging” cost sharing in their funding notices. This ambiguity breeds conflict with the intended purpose of the Uniform Guidance.

C. Under section 200.308 (c)(3) a recipient must request prior approvals from federal awarding agencies for the “disengagement from the project for more than three months…”, however, federal awarding agencies interpret “disengagement” differently. For instance, some agencies want notification, while others have provided no guidance as to its preference. It would be less burdensome if there was a unified approach among federal agencies.

D. FFATA is not consistently clear on National Institutes of Health (NIH) awards which adds administrative burdens when attempting to comply with the requirements.

E. Provide clear guidance on controlled information and foreign national restrictions.

F. Section 200.332 – Not all agencies are consistent about prior approval with some waiving the written pre-approval requirement, others are saying pre-approval is needed. NIH is waiving the requirement, while, the Office of Naval Research (ONR) and other agencies are requiring specific approval. ONR and Army Research Office (ARO) are requiring approvals.

G. Section 200.45 – federal awarding agencies are also not consistent with regard to whether a new subaward must be issued if the subaward is more than $150,000. UG requires approval, but some agencies (ONR/ARO) have advised that prior approvals are not necessary to modify a subaward with an anticipated amount above the $150,000 threshold. COGR says clarification came from OMB that more than one subaward can be issued to the same entity if there is a need to do so but each new subaward requires a distinct and separate SOW, budget, budget justification from the previously issued subaward. However, this guidance from COGR is not consistent with agency feedback as some are allowing modifications above the threshold.

non-standardized-processes

54 votes

Active

Active

Idea No. 45

Campaign Funnel

Campaign Activity

51 ideas posted
84 comments
3764 votes

UndefinedCampaign Owner

Campaigns

All Ideas
Contractors and Grantees
*To participate in the dialogue, you can submit a new idea by clicking "Submit New Idea" to the right, or you can vote and comment on existing ideas below.

Reporting compliance requirements shared by prime and subawardees of Federal procurements and grants
Key Participants: contractors, grantees, cooperative agreement holders, and subawardees
- Question: If you could change one thing that would ease your reporting burden associated with your awards, what would it be (e.g. time, cost, resource, other)?
- Question: If you have reporting requirements to the Federal government, how are those met?
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities or functions would you include?
9

3
Contractors
*To participate in the dialogue, you can submit a new idea by clicking "Submit New Idea" to the right, or you can vote and comment on existing ideas below.

Procurement practices, processes, and reporting
Key Participants: Contractors and subcontractors
- Question: If you could change one thing that would ease your reporting burden associated with your awards, what would it be (e.g. time, cost, resource, other)?
- Question: If you have reporting requirements to the Federal government, how are those met?
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities or functions would you include?
- Question: Are there any reporting areas in the FAR that are similar in nature to those in Federal agency supplements?
- Question: What other compliance information are you providing to the Federal government outside of the procurement process that could be used in procurement reporting and reduce duplication?
5

6
Grantees
*To participate in the dialogue, you can submit a new idea by clicking "Submit New Idea" to the right, or you can vote and comment on existing ideas below.

Grants practices and processes
Key Participants: grantees, cooperative agreement holders, subgrantees
- Question: If you could change one thing that would ease your reporting burden associated with your grants or subgrants, what would it be (e.g., time, cost, resource burden)?
- Question: If you have reporting requirements to the Federal government, how are those met? (feel free to be specific about what is reported to whom and through what mechanism)
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities/functions would you include?
OMB circular A-133:
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditee?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditor?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting to the Federal Audit Clearinghouse?
Uniform Guidance (2 CFR 200):
- Question: Are there requirements in the new 2 CFR 200 that need additional clarification for improved implementation with reduced administrative burden ?
- Question: What are the perceived burdens associated with the new standards such as the documentation of salaries & wages and time & effort (2 CFR 200.430), subrecipient monitoring (2 CFR 200.331), procurement standards (2 CFR 200.317- 2 CFR 200.324)?
- Question: How can the administrative burden associated with standards compliance be lowered?
51

84

Off Topic

Tags

Voting