Impacts of Uniform Guidance Updates on Sponsored Programs
Learn about the implementation impacts of the Uniform Guidance Updates on federally funded projects, including changes to financial assistance guidelines, F&A rates, and administrative procedures. Stay informed to ensure compliance with the new regulations effective from July 2024.
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Presentation Transcript
October 1st - Uniform Guidance Updates Implementation Impacts July, 2024 MRAM Post Award Fiscal Compliance - Matt Gardner Management Accounting & Analysis - Colleen Bettis Office of Sponsored Programs - Carol Rhodes
Impact to Sponsored Programs > To reflect scope, OMB renaming to Guidance for Federal Financial Assistance > Does not address Federal Acquisition Funding or Other Transaction Authority (OTA) instruments. > Changes in the Guidance for Federal Financial Assistance do impact all sponsored programs, via UW policy, processes and internal controls/systems. > We will cover highlights and timing of implementation. Replacement for Uniform Guidance, effective 10/1/2024
UG Revisions impacting F&A and Fringe Rates > Three Primary changes Increases subawards included in the MTDC from $25k to $50k Increases Equipment Capitalization threshold from $5K to $10k Treatment of Separation Leave (additional guidance expected later this CY) > MTDC changes effective on next F&A proposal MAA currently developing FY23 F&A proposal under current UG > targeted submission 9/30/24 MAA will submit impact statement with revised UG rules > targeted submission by 12/31/24 Implementation of new thresholds will require renegotiation of FY23 rates or next rate proposal > Separation Leave - additional guidance expected later CY24
Practical example for budgeting purposes Include proposal budget information for a one year versus multiple year budget. > Do we use existing $5000 equipment threshold? Yes > Do we still only charge UW F&A on the first $25,000 of an outgoing subaward? Yes What about our subrecipients? Not changing > If they implement right away, their MTDC can differ from ours. That is acceptable (as it is now)
Other UG changes Pre-Award/Time of Award > Terminology updates: Key Personnel defined Participant defined > Notice of Funding Opportunity (NOFO) template > Prior Approval Definition updated to add obtained in advance Removed of prior approval requirements of 9 items Prior approval matrix hosted on NSF site will likely be updated Subawards Administrative Changes > Fixed amount subaward: Maximum raised to $500,000 > Single audit threshold increased to $1 Million in federal expenditures (from $750,000) > De minimus F&A rate from 10% to 15%
Other Post Award UG Changes - Participant Support > OMB has removed the phrase but not employees from the definition under 200.1 > Participants must be individuals: Participating in or attending program activities under a Federal award, AND Are not responsible for implementation of the Federal Award. > Individuals which are not considered participants: Consultants Project personnel Staff members of recipient Participant Support | Post Award Fiscal Compliance (uw.edu)
Other UG Notes - Program Income > OMB stressed that program income must be expended before requesting additional payments stating that this is a long-standing feature of section 200.307 on program income. > Translation: Recipients cannot keep excess program income. Any surplus program income must be used to offset the Federal share of expenditures. Program Income | Post Award Fiscal Compliance (uw.edu)
