recent changes published in part 200 uniform guidance -- cost principles steve bradley,
DESCRIPTION
Recent Changes Published in Part 200 Uniform Guidance -- Cost Principles Steve Bradley, Director. Agenda. New Structure (“Roadmap”) Highlighting relevant F&A and Cost Principle sections Costing Principles Including eliminations of prior A-21 sections MAXIMUS Impact Assessment - PowerPoint PPT PresentationTRANSCRIPT
1
Recent Changes Published in
Part 200 Uniform Guidance
-- Cost Principles
Steve Bradley,
Director
2
Agenda
– New Structure (“Roadmap”)• Highlighting relevant F&A and Cost Principle sections
– Costing Principles• Including eliminations of prior A-21 sections• MAXIMUS Impact Assessment
– Resources
3
Structure (cont.)
– Subpart E – Cost Principles (A-21, A-87, A-122)
• General Provisions § 200.400 to 401
• Basic Considerations (Cost Allowability, Applicable credits)
§ 200.402 to 411
• Direct and F&A Costs (including required Certifications)
§ 200.412 to 415
• State, Local & Indian Govt § 200.416 to 417
• Special Considerations for Institutions of Higher Education
§ 200.418 to 419
• General Provisions for Selected Items of Cost (Prior A-21, section J)
§ 200.420 to 200.475
4
Structure (cont.)
– Subpart F – Audit Requirements (A-133)
– Appendices (combination of all 8 Circulars)• I – Notices of Funding• II – Contract Provisions• III -- F&A for Educational Institutions (A-21)• IV – Indirect for Non-Profits (A-122)• V – State/Local Cost Allocation Plans (A-87)• VI – Public Assistance (A-87)• VII – State/Local Indirect Cost Plans (A-87)• VIII – Non-Profit Exemption from Cost Principles (A-21)• IX – Hospitals (TBD)• X – Audit Data Collection (A-133)• XI – Single Audit Compliance Supplement (A-133)
5
OMB Changes – Combine Circulars
• Consolidate A-87, A-21 and A-122 Cost Principles
• Create a common accounting standards for all grant recipients
IMPACT
--Probably add more confusion than clarity
--Universities are much different than Non-profits and State/Local Govt’s
--Document littered with “exceptions” (e.g., A-21 26% Admin cap )
6
OMB Changes – Flat Rate
• For F&A costs, use a flat rate instead of current negotiated rate system – NOT in new guidance
IMPACT
GREAT!
•Flat / “tiered” rate idea was not well received and has been dropped
7
OMB Changes – UCA (App. III B.4.c)
• Maximum 1.3 Utility Cost Adjustment with “Utilities” allocations based on “Effective square footage”
• ESF is actual SF times “Relative Energy Utilization Index (REUI)• REUI is currently 2X• OMB will adjust factor “no
more often than annually nor less often than every 5 years”
• Allows metering at a Sub-Building level????
IMPACT
GREAT (for some)!
Increase burden (for others)!
•Perhaps a Double-Edged Sword?
•Schools will now have to develop data for their Utilities pools
•“Separate Proposal”
8
OMB Changes – Eliminate Required Study
• Eliminate requirement for institutions to conduct studies for cost reasonableness for Large Research Facilities
• prior A-21, F2
IMPACT
--GREAT!
--Reduce administrative burden
9
OMB Changes – Eliminate Mandated F&A Usage
• Eliminate requirement that certain institutions must use F&A recoveries associated with depreciation to acquire or renovate research buildings or equipment
• prior A-21, J14h
• Currently applies to 99 schools
IMPACT
--GREAT!
--Reduce administrative burden
10
OMB Changes – Eliminate Required Analysis
• Eliminate requirement that schools perform a Lease Purchase Analysis to justify External Bond Interest
• prior A-21, J26
• now Subpart E, 200.449
IMPACT
--GREAT!
--Reduce administrative burden
--But, Retained “25% Equity Contribution” rule
11
OMB Changes – DS-2 (Subpart E, 200.419)
• Disclosure Statements (DS-2) & Compliance under the Cost Accounting Standards Board (CASB), retained (prior A-21, C14)
• Threshold raised from $25M to $50M
• Added: University proposed change must be submitted to DCA/ONR 6 months in advance
IMPACT
--Reduce administrative burden?
Change in effect next FY unless hear from DCA/ONR
12
OMB Changes – 10% Rate for First-timers
• Addition of 10% de-minimus indirect cost rate (modified total direct cost basis) for entities that do not currently have a negotiated rate
• Subpart E, 200.414
IMPACT
GREAT!
--May reduce the need for university staff to review indirect proposals from these type sub awardees / subcontractors
13
OMB Changes – Cost Sharing
• Affirm that Voluntary Committed Cost Sharing is NOT expected & is NOT to be used as a factor in review of applications
• Subpart D, 200.306
• Only mandatory cost sharing and cost sharing specifically committed in the project budget must be included in the organized research base
IMPACT
GREAT!
--Probably reduce administrative burden and/or Organized Research “base”
--VUCS clarification still in effect
14
OMB Changes – Direct Charging of Admin.
• Salaries of administrative staff may be direct charged to federal grants where ALL of the following are met:• Services are integral to the
project • Individuals can be specifically
identified to the project • Explicitly included in the
budget or have prior written approval
• AND, are not recovered as indirect costs
• Subchapter E, 200.413
IMPACT
DOUBLE-EDGED SWORD!
--May reduce confusion
--But may increase the Organized Research MTDC base and, in turn, lower proposed rates
--As offset, F&A rates would be applied to these new direct costs, increasing F&A Dollar Recoveries
15
OMB Changes – Rate for All Agencies
• Require Federal agencies to accept negotiated indirect (F&A) cost rates, unless an exception is required by statute or regulation; and, Federal agency must notify OMB of any approved deviations
• Subpart E, 200.414
• IMPACT
• Regrettably, not much change• Except, OMB will now have central repository of these
• For example, USDA, 8% Training grants, etc., will probably stay at reduced F&A rates
16
OMB Changes – Effort Certification
• Remove the “Examples of Acceptable Methods for Effort Certification for Payroll Distribution”
• Emphasis on “Internal Controls” and “Performance”
• prior A-21, section J10
• Subpart E, 200.430
IMPACT
•Reduces Effort Certification burden•Allows “flexibility in how universities can meet standards”•“Final guidance does not require current PAR’s/similar documentation”•Also, FDP doing their own “Project Certification” Demo, including reviews by OIG’s
17
OMB Changes – Rate Extension
• All Non-Federal entities may apply for a one-time extension of current F&A rates for up to four years, subject to cognizant agency approval
• Subpart E, 200.414
•IMPACT
•May be appropriate for some universities
•For others, may reduce F&A dollar Recoveries (e.g., if major new research buildings, if now eligible for UCA, or substantial decrease in base re: end of ARRA grants)
18
OMB Changes – Computing Devices
• Addition of new language which allows “Computing devices” and associated support costs to be treated as allowable and allocable direct costs
• Subpart E, 200.453
IMPACT
DOUBLE-EDGED SWORD!
•May reduce confusion
•But may increase the Organized Research MTDC base and, in turn, lower proposed rates
•As offset, F&A rates would be applied to these new direct costs, increasing F&A Dollar Recoveries
19
OMB Changes – MTDC (App. III C.2)
• App. III C.2. references section 200.68 where participant support costs, defined in 200.75, are listed as an exclusion to MTDC
• Other items may only be excluded when necessary to avoid a serious inequity in distribution of indirect costs, and with the approval of the cognizant agency
IMPACT
-- Perhaps increase burden to identify new exclusion
-- Possibly deter agencies adding unfair base exclusions (e.g. genomic arrays)
20
OMB Changes – Library Expenses (App. III B.8)
• The professional employee category can include post-doctorate fellows and graduate students
• The other users category can be based on a reasonable factor as determined by institutional records to account for all other users of library facilities
IMPACT
--GREAT!
--Support standard practice allocation to postdocs and grad students
--Reduce administrative burden
21
OMB Changes – Dual Role of Students
• Kept language stating “ … the dual role of students as both trainees and employees contributing to the completion of Federal awards for research must be recognized in the application of these principles.”
• Subpart E, 200.400(f)
IMPACT
--GREAT!
--May have reduced F&A rates if omitted
22
Unresolved Issues
• When will revised DCA Best Practices Manual be published?
• UCA for FY14 base year F&A rate proposals?
• Definition of “monitored research laboratory space” re: UCA
• Format for “separate calculation proposal” for UCA
• Does “one time” extension mean once in the life of the rate or once in the life of the institution
• Send questions to COFAR [email protected]
23
Resources
http://www.maximus.com/our-services/education/higher-education/omb-uniform-guidance
• Federal Register article: Web | PDF• 2 CFR Part 200: eCFR - Code of Federal Regulations• The OMB website includes many helpful links:
• OMB Policy Statements: Uniform Grant Guidance• Crosswalk from Existing Guidance to Final Guidance• Crosswalk from Final Guidance to Existing Guidance• Cost Principles Comparison Chart • Audit Requirements Comparison Chart • Definitions Comparison Chart• Administrative Requirements Comparison Chart• COFAR
24
Contact Us
Email: [email protected]
Telephone: 800-709-2747
Website: http://HigherEducation.MAXIMUS.com
Facebook: MaximusHEP
Twitter: #MaximusHigherEd