Uniform Administrative Requirements Final Guidance

Uniform Administrative Requirements Final Guidance

On Thursday, December 26, 2013 the Office of Management and Budget (“OMB”) published in the Federal Register | Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. In brief, OMB is streamlining the guidance currently in effect for Administrative Requirements (OMB Circulars A-89, A-102 and A-110), Cost Principles (OMB Circulars A-21, A-87 and A-122), and Audit requirements (OMB Circulars A-50 and A-133) for Federal awards by consolidating 8 Circulars into 1 consolidated publication.
The intentions of this reform of OMB guidance are to:

  1. Reduce the administrative burden on non-Federal agencies and
  2. Reduce the risk of waste, fraud and abuse.

As stated in this guidance:

As stated in this guidance, “The goal of this reform is to deliver on the President’s directives to (1) streamline our guidance for Federal awards to ease administrative burden and (2) strengthen oversight over federal funds to reduce risks of waste, fraud and abuse.”

THE GUIDANCE HAS IDENTIFIED NINE MAJOR POLICY REFORMS

  1. Eliminating Duplicative and Conflicting Guidance
  2. Focusing on Performance over Compliance
  3. Encouraging Efficient Use of Information Technology and Shared Services
  4. Providing for Consistent and Transparent Treatment of Costs
  5. Limiting Allowable Costs to Make Best Use of Federal Resources
  6. Setting Standard Business Processes Using Data Definitions
  7. Encouraging Non-Federal Entities to Have Family-Friendly Policies
  8. Strengthening Oversight
  9. Targeting Auditing Requirements on Risks of Waste, Fraud and Abuse

THE NEW GUIDANCE IS SEGREGATED INTO THREE MAIN GROUPS

  • Subparts A-D: Reforms to Administrative Requirements
  • Subpart E: Reforms to Cost Principles
  • Subpart F: Reforms to Audit Requirements

SUBPARTS A-D

The reforms to the administrative requirements which are discussed in Subpart A, include definitions and acronyms used throughout the guidance. One notable change is to include computing devices with a unit cost of less than $5,000 in the definition of Supplies. Subpart B discusses general provisions and is also where the effective date is identified. The audit requirements identified in Subpart F will be effective for fiscal years beginning on or after December 26, 2014. So realistically, the effective date is for calendar year ending December 31, 2015. For June year end Agencies, which is a common year end for not-for-profits, specifically those in New Jersey, the effective date would be for periods ended June 30, 2016. Pre-Award requirements are addressed in Subpart C, while Subpart D discusses Post-Award requirements.

Subpart E and F overviews will be released in the upcoming weeks.

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The information contained herein is not necessarily all inclusive, does not constitute legal or any other advice, and should not be relied upon without first consulting with appropriate qualified professionals for your individual facts and circumstances.

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