Per the DOD’s Interim Implementation (2 CFR Part 1103), awards made to MIT after December 26, 2014 are “subject to the administrative requirements, cost principles, and audit requirements” of 2 CFR Part 200 (Uniform Guidance or “UG”). Special exceptions may be made for new awards under $150,000.
The AFOSR and ARO have not yet issued agency-specific guidelines that implement the Uniform Guidance. Any requests for prior approval should be submitted in writing to RAS for review; RAS will then submit to the grants officer by RAS.
- Period of Performance Extensions
- May incur pre-award costs 90 days prior to the award date without prior approval.
- Research awards may initiate a one-time no- cost extension of up to 12 months by notifying agency in writing at least 10 days prior to award expiration.
- Personnel Changes
- Change of any key person named in proposal or award requires prior approval.
- Disengagement of the PI for 3 months requires prior approval.
- 25% reduction in effort PI requires prior approval.
- Restrictions on Allowable Costs
- Subject to Uniform Guidance without further restriction
- Rebudgeting authority:
- All deviations from the approved budget are required to be reported to the Agency.
- Funds for participant support may not be rebudgeted without prior approval.
- Changes in Cost sharing require prior approval.
- Carry Forward
- Carryforward does not require prior approval.
- Equipment/Property
- Unbudgeted Special purpose equipment over $5,000 may not be purchased without prior approval.
- Unbudgeted General purpose equipment of any value may not be purchased without prior approval.
- Title to property vests in MIT.
- Property management and reporting requirements are applicable to all property for which MIT is accountable under an award.
- Travel
- Use of U.S. Carriers for flights is required per the Fly America Act (49 USC 40118)
- The Department of Defense does not allow exceptions under the Open Skies Agreements.
- Publications
- Acknowledgment required: Not specified in the regulations, but typically expected in all releases of information
- Disclaimer required: Not specified in the regulations, but typically expected in all releases of information except scientific articles.
- Copies to Sponsor: Not specified in the regulations, but typically expected to Technical Representative at the time of submission for publication.
- Subcontracting
- Prior Approval required for all unbudgeted subcontracting.
- Reporting
- Requirements shall be specified in the Award document.
- Technical reporting must be completed by the PI.
- Final technical report must be submitted to ospaward@mit.edu in addition to any recipients specified in award document.
- Requirements may vary, but typically include
- Annual reports due on the anniversary of the effective date,
- Final report, including Standard Form (SF) 298, due 90 days after closeout.
- Financial Reporting required, completed by Sponsored Accounting.
- Intellectual Property Reporting required, completed by RAS
- Property/Equipment Reporting may be required. Completed by Property Office