Purpose & Objectives of the Uniform Guidance
The Uniform Guidance (UG) provides a government-wide framework for grants management. The UG joins additional efforts to strengthen program outcomes through innovative and effective use of grant-making models, performance metrics, and evaluation.
The UG’s main objectives are to streamline the rules and regulations for federal awards, to reduce administrative burden, and to mitigate the risk of waste, fraud and abuse of federal funding for non-federal entities receiving Federal awards.
History & Timeline of the Uniform Guidance (UG)
- On December 26, 2013, the Office of Management & Budget (OMB), the Council on Financial Assistance Reform (COFAR), and eight federal awarding agencies were published in the Federal Register under the joint interim final rule of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards.
- On June 26, 2014, as mandated by OMB, the federal granting agencies were required to release their UG Implementation plans to OMB with final versions published on or before 12/26/2014.
- On December 19, 2014, Health & Human Services were published in the Federal Register, the interim final rule adopting OMB’s final guidance in 2 CFR, Part 200.
- On December 26, 2014, the final Uniform Guidance went into effect.
- In the past, there were three OMB circulars that governed Weill Cornell Medicine’s management of awards subject to federal government administrative requirements, cost principles, and audit requirements:
1. A-21 – Cost Principles
2. A-110 – Administrative Requirements
3. A-133 – Audit Requirements
- The UG replaces eight of the previous OMB circulars (which include A-21, A-87, A-89, A-102, A-110, A-122, A-133 and Circular A-50/Single Audit Act) into one Uniform Circular.
Navigating the Uniform Guidance
The Uniform Guidance is broken down into one (1) Preamble, six (6) Subparts, and eleven (11) Appendices.
|Pre-Federal Award Requirements and Contents of Federal Awards|
Goals & Intended Impact of the UG
- Eliminate Duplicative and Conflicting Guidance
- Performance over Compliance for Accountability
- Efficient Use of IT and Shared Services
- Consistent and Transparent Treatment of Costs
- Limiting Costs for Best Use of Federal Services
- Standard Business Processes & Data Definitions
- Family Friendly Policies
- Stronger Oversight
- Target Audits on Risk of Waste, Fraud and Abuse
WCM UG Implementation: Tools, Forms & Resources
Weill Cornell Medicine’s Office of Research Administration convened three separate UG Implementation Teams to analyze changes that the UG would impose on WCM policies and procedures. The Office conducted an extensive gap-analysis to assess needed changes to existing policies and procedures. As a result of the hard work and commitment of these teams, several tools and resources were created to assist the WCM research community with processing the UG:
- WCM UG Implementation Guidebook*
- Admin-Clerical Guide Graphic
- Admin-Clerical Prior Approval Request Instructions & Internal Template Letter
- Admin-Clerical Budget Justification Guidance
- WCM Computing Device Guide
- UG 4-tests of Allowability Matrix
- Prior Approval Matrix
- Updated policies
*The WCM Uniform Guidance Implementation Guidebook is a reference tool created to highlight key changes in the regulations that will impact day-to-day grant management activities. Additionally, this tool was created to address WCM's approach to implement these changes. The guidebook is not intended to be all-inclusive of every change the UG presents but to simply highlight key changes.
Additionally the following policies and procedures were updated to comply with the UG:
- Effort Reporting and Tracking Plan
- Cost Sharing Policy and Procedures
- Cost Transfers on Sponsored Projects Policy
- Direct Costs Policy
A complete list of WCM Research Administration and Finance policies can be found here.
WCM UG Implementation Teams
The WCM UG implementation teams are comprised of:
UG Steering Committee (SC)
WCM UG Steering committee convened in Spring 2014. The committee included experts in pre- and post-award administration, costing policy, audit, purchasing, and equipment management from central administration.
- Provide leadership, oversight, and direction to assigned workgroup(s).
- Develop and assess overall progress of the WCM UG implementation and perform necessary tests of compliance.
- Assess scope of new regulations vis-à-vis WCM policy and procedures.
UG Workgroups (WG):
The UG WGs include central and departmental campus experts in the fields of pre- and post-award administration, costing policy, audit, purchasing, and equipment management.
- Recommend actions needed at the system-wide and local levels for WCM policy/procedures to adapt to the UG terms and conditions.
UG Department Contributors (DC):
The UG DCs were a critical component to WCM’s implementation of the UG. Team members convened for several multi-hour sessions to review the implementation plan. The group also reviewed the development of tools and resources for the use of the WCM research community in response to the impact the UG would have on policies and day-to-day grant management procedures.
- The WCM-UG department is comprised of WCM department representatives who provide feedback on WCM UG implementation tools.
- Review and provide input on training materials and tools to assist research community with implementation.
- R.A.P.I.D: March 16, 2015
- R.A.P.I.D: September 14, 2015
- R.A.P.I.D: May 11, 2015
- Campus Review Sessions: September 22 & 23, 2015