Overview of Changes

Administrative and Clerical Staff
Closeouts
Compensation - Personal Services
Computing Devices
Conferences
Cost Sharing
Investigator Disengagement
Participant Support Cost
Procurement
Publication Costs
Subaward
Visa Costs

Uniform Guidance

Access: https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200 

Administrative and Clerical Staff

Administrative or clerical staff must be integral to a project in order to be a direct charge to a federal award and must be included in the budget and budget justification or have prior written approval from the sponsor.

Under the Uniform Guidance, a project no longer needs to be identified as "major" to include administrative salary, but normally these expenses should be treated as Facilities & Administrative costs unless they meet the following conditions:

  • essential or vital to the project, and described accordingly in the justification
  • budgeted at a percentage of a person-month that reflects that essential nature
  • performed by individuals specifically identified with the project or activity
  • costs that are not also recovered as indirect costs

Administrative or clerical staff may be direct charged to non-federally sponsored projects, provided they benefit the project and follow the sponsors' requirements for the award.

Applicable Uniform Guidance section: 200.413.

Closeouts

Uniform Guidance requires that all reports related to a federal award are submitted no later than ninety (90) calendar days after the end date of the period of performance. This includes all financial (including subaward) reports and invoice payments, and technical and patent reports. Federal agencies will not allow cash draws on awards ninety (90) calendar days after the project's end date, except in exceptional cases, as approved by the responsible agency.

To avoid having to cover costs, awards should be monitored throughout the life of the project and incorrect or unallowable charges eliminated. Subrecipient reports must be completed in a timely manner. Principal Investigators are responsible for completing all final reporting requirements.

Applicable Uniform Guidance sections: 200.16 and 200.343.

Compensation - Personal Services

Compensation for employees engaged in work on Federal projects will be based on the employee’s Institutional Base Salary (IBS). IBS is defined as the annual compensation paid by the University of Arizona for an individual's appointment, whether that individual's time is spent on research, instruction, administration, or other activities.

IBS excludes any income that an individual earns outside of duties performed for the University. Unless there is prior approval by the Federal awarding agency, charges of an individual’s salary to a Federal award must not exceed the proportionate share of the IBS for the period during which the individual worked on the award.

The IBS rate must be used as the base salary on all grant proposals. For effort reporting purposes, total institutional effort is 100% effort, regardless of the individual’s appointment (e.g., 1.0 FTE, 0.5 FTE, .75 FTE). No individual may commit more than 100% institutional or summer effort or be compensated at a rate that would exceed their annualized institutional base salary

Applicable Uniform Guidance section: 200.430.

Computing Devices

OMB Uniform Guidance defines computing devices as “machines used to acquire, store, analyze, process, and publish data and other information electronically, including accessories (or “peripherals”) for printing, transmitting and receiving, or storing electronic information”.

Computing devices that cost less than $5,000 can be charged as direct material and supplies costs to a Federal project if the devices are essential and allocable. They do not need to be solely dedicated to the project.

The purchase of computing devices on a Federal project should be justified in the proposal as essential and allocable and the direct benefit of these devices should be documented during the project.

Applicable Uniform Guidance section: 200.20 and 200.453.

Conferences

Expenses for conference (defined in the Uniform Guidance as meetings, retreats, seminars, symposia, workshops, or other events), including food and beverages, may be allowable provided the primary purpose is  dissemination of technical information beyond the University of Arizona  The meeting must be necessary and reasonable for successful performance of the award. Federal agencies expect conference hosts to exercise discretion and judgment in ensuring that conference costs are appropriate, necessary and managed in a manner that minimizes costs to the Federal award.

Allowable conference costs paid by the University of Arizona as a sponsor or host of the conference may include rental of facilities, speakers' fees, costs of meals and refreshments, local transportation, and other items incidental to such conferences unless further restricted by the terms and conditions of the Federal award.

As needed, the costs of identifying, but not providing, locally available dependent-care resources are allowable.

Standard group meetings in which information is shared among laboratory members do not qualify as allowable costs.

Applicable Uniform Guidance section: 200.432.

Cost Sharing

Cost sharing or matching funds are those portions of the project costs not paid for by Federal funds. 

Voluntary committed cost share is cost share specifically pledged by the University of Arizona in the proposal.  It becomes a binding part of the Federal award to which it is pledged. Voluntary cost sharing is not expected in federal research proposals. It cannot be used as a factor during the merit review unless it is specified in the funding opportunity notice.

No cost sharing should be included in a proposal unless it is specifically required by an agency's funding solicitation. If cost sharing is required in the solicitation, it should be included in the proposal budget and should meet other federal requirements for cost-sharing eligibility.

Applicable Uniform Guidance section: 200.29, 200.99; and 200.306.

Investigator Disengagement

The Uniform Guidance recognizes that Principal Investigators (PIs) can be engaged in projects even if not physically on-campus. Agency prior approval is required for PI disengagement (formerly “absence”) from the project for more than three months or a 25% reduction in effort.

PIs must submit a request through Sponsored Project Services for prior approval from the Federal sponsor if they will be disengaged from any project for more than three months or if there is a 25% reduction in time committed to the project from the approved budget. If a PI is actively engaged in a project, even if offsite, such approval is not required.

Applicable Uniform Guidance section: 200.308.

Participant Support Cost

Participant support costs are defined in the Uniform Guidance as direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects.

Participant Support Costs are also only allowable with prior approval from the Federal agency. When preparing your budget, these costs must be explicitly listed in the proposal budget or approved by the Federal agency after the award has been made.

For National Science Foundation awards, the University’s segregates participant support costs from other grant expenditures by utilizing a sibling account for the participant support budget and expenditures.  For other sponsors, Participant Support costs may be accounted for in the parent account or a sibling account depending upon sponsor specific terms and conditions and at the discretion of SPS and the administering department.  Documentation of expenditures follows University Financial Management policies and procedures.   Documentation of attendance of participants at workshops, symposia, etc must include a list of attendees and an agenda.

Any rebudgeting of Participant Supports Costs to another budget category requires the approval of the Federal agency.  For NSF awards, the rebudgeting request must be entered in Research.gov.  For other sponsors, refer to the award notice.

A participant is the recipient, not the provider, of a service or training opportunity as part of a workshop, conference, seminar, symposium or other short-term instructional or information sharing activity funded by a sponsored award.  In rare circumstances, an employee may be considered a participant if their participation is unrelated to their UA employment.

Human subject incentive payments are not considered participant support.  Subject pay provides compensation or incentives to individuals serving as subjects in research studies, while participant support stipend payments support participation in sponsored project funded conferences, workshops, and training activities.

Per Uniform Guidance, Participant Support Costs are a standard exemption category when using a Modified Total Direct Cost Base. Therefore, this line item should be excluded from the base when calculating the F&A costs when using our federally negotiated rate.

Applicable Uniform Guidance section: 200.68 and 200.75

Procurement

Competition:  Uniform Guidance Memo M-18-18 dated June 2018 formally publishes the Uniform Guidance micro-purchase, (also known as small dollar purchase), threshold as $10,000. UA has adopted this threshold. Purchases over $10,000 require buyer substantiation of selected source and pricing. Please see UA Purchasing Policies and procedures for more information:

Applicable Uniform Guidance section: 200.67 and 200.320.

Publication Costs

The Uniform Guidance allows the costs of publication or sharing of research results to be charged before the Federal award closeout if the costs are not incurred during the period of performance of the award. Please contact your fund accountant for guidance.

Applicable Uniform Guidance section: 200.461.

Subaward

Subrecipient Monitoring: The Uniform Guidance requires increased scrutiny of the subrecipient at the time of proposal and increases emphasis on risk analysis prior to issuing a subaward. Subawards must be carefully evaluated and monitored through the life of the award and additional oversight measures may be required based on the risk level of the subaward institution.  The Guidance stresses the need for the University of Arizona to document and perform subrecipient monitoring. 

Fixed Price Subawards:  Fixed price subawards of up to $150,000 are permissible under the Uniform Guidance, with prior sponsor approval.

de Minimis F&A Rates: The Guidance allows the University of Arizona to provide a de minimis F&A rate of 10% modified total direct costs (MTDC) to subawardees who do not have a federally negotiated rate. Subaward budgets to the University should clearly state whether the de minimis indirect costs are being used.

For subawards to foreign organizations, NIH limits the reimbursable F&A costs to 8% of the modified total direct costs (MTDC), less only capital equipment.

Applicable Uniform Guidance sections: 200.331, 200.332, and 200.414.

Visa Costs

Short-term nonimmigrant, travel visa costs (as opposed to long-term, immigration visas) are generally allowable expenses that may be proposed as a direct cost for the recruitment of an individual to work on a project. Since short-term visas are issued for a specific period and purpose, they can be clearly identified as directly connected to work performed on a Federal award. The US Department of State defines visas as: 

An example of an allowable short term nonimmigrant visa are J-1 and H-1B visas which are for temporary travel and employment. Immigrant visas for travel to live permanently are not allowable on Federal awards. 

Generally only the initial visa cost for recruiting an individual for the project is allowable. Renewal visa costs for existing employees may not be an allowable expense. Therefore, the length of the project should be considered when choosing a timeframe for the initial visa.

For these costs to be directly charged to a Federal award, they must:

  • Be critical and necessary for the conduct of the project
  • Be allowable under the applicable cost principles
  • Be consistent with the University's cost accounting practices and policy
  • Meet the definition of a "direct cost" as described in the applicable cost principles

Basic visa application and required fees, such as anti-fraud fees, are allowable direct costs provided they meet the definition above.

Prior approval by the funding agency is not required but, because short-term, travel cost visas are classified as recruiting costs, only the cost of the initial visa is allowable.

Premium processing fees, dependent form fees, or University of Arizona internal processing fees are NOT allowable as direct charges to a federal award.

If the employee resigns within twelve (12) months of recruitment, for reasons within their control, the associated relocation costs, including any visa costs, must be removed from the Federal award.

Applicable Uniform Guidance section: 200.463(d).