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Uniform Guidance (2 CFR 200)
On December 26, 2013, the Office of Management and Budget (OMB) issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements (Uniform Guidance or 2 CFR 200) for federal awards. The Uniform Guidance streamlines and supersedes guidance previously contained in eight separate OMB Circulars. Included in the new guidance are uniform administrative requirements (pre and post-award), cost principles, audit requirements, and definitions.
The University has moved forward to update its policies and procedures with the exception of the Procurement Policy which the University accepted the one year extension provided. The new Procurement guidelines will take effect July 1, 2016.
*Important to note for Sponsored Projects, the Uniform Guidance supersedes OMB Circulars A-110, A-21, and A-133
Immediate changes to be included in proposals:
Direct Charging Salaries of Administrative & Clerical Staff
GW’s policy reflects section 200.413 of the Uniform Guidance, which establishes the principle that salaries of administrative and clerical staff should normally be treated as Facilities & Administrative (F&A) or indirect costs. It also reflects the circumstances where it is appropriate to charge administrative expenses directly to federally sponsored projects. 2 CFR 200 eliminates the “major project” standard from A-21 for the direct charging of administrative and clerical salaries.
Direct charging of these costs to federally sponsored projects is a appropriate only if ALL of the following conditions are met:
- Administrative or clerical services are integral to a project or activity
- The requirement that the costs is "integral" means the services are essential, vital, or fundamental to the project or activity.
- Individuals involves can be specifically identified with the project or activity;
- Such costs are explicitly included in the budget or have prior written approval of the federal awarding agency;
- A budget justification must be included in the proposal.
- The costs are also not recovered as indirect costs.
Federal awards received before December 26th, 2014 must continue to follow the requirements of OMB A-21 and GW’s policy on Direct Charging of Administrative Costs Associated with Sponsored Projects.
- Federal Register - 2 CFR 200
- Council on Financial Assistance Reform (COFAR) – 8/29/2014 Frequently Asked Questions
- COFAR's "Uniform Guidance Implementation: A Conversation Presented by the Council on Financial Assistance Reform" - Webinar