On December 26, 2013 the Office of Management and Budget (OMB) released its final rule of “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (2 CFR Chapters I, II, Part 200, et al), and later provided interim updates.
This guidance to federal agencies consolidates and replaces eight OMB Circulars such as the A-110 (Administrative requirements), A-21 (Cost principles), and A-133 (Audit requirements). The Uniform Guidance (UG) applies to all new federal awards issued on or after December 26, 2014. Modifications adding new funding to awards issued prior to that date may also include a clause updating the terms of the award to fall under UG.
Federal agencies (NIH, NSF, Dept of Energy, etc) have each developed their own agency-specific implementation plans for the Uniform Guidance. The plans for some agencies adopt the Uniform Guidance in its entirety. Other agencies list specific exceptions. It is necessary to review the Uniform Guidance, the sponsoring agency’s implementation plan and the award terms to determine what rules will apply to any new federal funding.
Note that Federal-wide Research Terms and Conditions (RTC), including waiver of prior approvals and other requirements, have now been finalized. Contact your RAS representative if you have any questions.
- December 26, 2013 – OMB issued the final rule of the Uniform Guidance (UG).
- December 19, 2014 – Joint Interim final rule published: Includes OMB updates to UG and Federal agency-specific plans for implementing UG.
- December 26, 2014 – UG went into effect.
- July 1, 2015 – Uniform Guidance audit requirements are applicable to MIT awards.
- October 14, 2015 - Proposed Federal Research Terms & Conditions for the Uniform Guidance posted for public comment
- March 14, 2017 – Federal Research Terms and Conditions and Prior Approval Matrix published.
- July 1, 2018 – Uniform Guidance procurement requirements are applicable to MIT awards.
Navigating the Uniform Guidance
Information can be found more easily by understanding that the Uniform Guidance is broken down into Subparts. The preamble also provides a useful framework and discussion of how certain guidelines were ultimately determined.
Preamble – Major Policy Reforms
Subpart A – Acronyms and Definitions
Subpart B – General Provisions
Subpart C – Pre Award Requirements
Subpart D – Post Award Requirements
Subpart E – Cost Principles
Subpart F – Audit Requirements