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OMB circular A-133:
Uniform Guidance (2 CFR 200):
The OMB Compliance Supplement for the Single Audit increased the threshold for known or likely questioned costs from $10,000 to $25,000. Princeton University suggests that consideration should be given for a threshold higher than $25,000, particularly when extrapolation could occur throughout the rest of the organization. An alternative solution would be to make the threshold related to a percentage of expenditures ...more »
Princeton University suggests that the Federal Audit Clearinghouse (FAC) should provide more guidance (e.g. definitions, acronyms) on how to access and leverage annual reports to monitor subrecipients per Uniform Guidance requirements in order to reduce the burden. Assistance in navigating through the forms similar to guidance provided to comply with the Federal Funding Accountability and Transparency Act (FFATA) would ...more »
Codify the Frequently Asked Questions (FAQs) to eliminate potential interpretation differences of future auditors and inspectors general between Uniform Guidance and FAQs.
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 ...more »
Given that the main product of federally-funded research is typically publications, Princeton University suggests that it would seem sensible to allow submission of PDFs of publications where they have already appeared as a result of the work funded by the grant, and reduce the reliance on extensive research summaries. If nothing has been published, then it makes sense to ask for a report on preliminary progress. NSF ...more »
Faculty at Princeton University find it frustrating that each agency requires different data in different formats and that not all the web portals work well. For example, the DOE-BES PAMS system does not always save entries, and this can lead to loss of edits. Clicking to save an entry often takes the PI to the login page, often resulting in loss of data. So having a robust portal that automatically saves data entered ...more »
PIs at Princeton University spend a large amount of their time during proposal preparation on compliance approvals. One recommendation would be for the federal government to impose a pre-compliance standard at submission, which could include a document from the sponsored research office listing areas where they know that strict compliance has not been met. The compliance can then be fully implemented once/if the proposal ...more »
The government should make efforts to reduce focus on the micro accounting of grant expenditures and move towards a system where the peer review process and program managers base future funding decisions on broader measures of appropriate expenditures of cost. Princeton University suggests that one useful guide might be the IRS rules: in general, any expenditure that would normally be considered taxable income (apart ...more »
OMB should clarify the parameters for the risk analyses that universities are required to make for their subrecipients under the Uniform Guidance. Such a move would help to curtail the proliferation of individualized standards or action plans established by individual universities seeking to carry out their responsibilities under the as prime recipients with respect to their subrecipients.
Limit the public release of federal audit reports until they have been validated through audit resolution. Since universities are reputation-based organizations, great harm can result from premature release of audit reports that are later found to be out of step with agency policy. In addition, and as a result of some universities efforts to be 100% compliant, premature release of audit reports can result in the enactment ...more »
A single, central reporting portal for all reporting would help achieve the goals of the DATA Act. A central portal should provide the following functions: 1) One Portal a. The goal is to have one place for recipients to report on research expenditures. b. All the agencies conform from the beginning. i. If exceptions are granted, it should be clearly documented who has been granted an exception and, the length of time ...more »
Enactment of the Digital Accountability and Transparency Act in May, 2014 provides many opportunities for the Office of Management and Budget and the Department of Treasury to improve the public transparency of Federal spending while simultaneously reducing the overall reporting burden on both Principal Investigators and institutional Research Administrators. However, there are also many implementation scenarios that ...more »