Uniform Guidance Basics

First implemented in 2014, the Office of Management and Budget’s (OMB) “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (2 CFR Chapters I, II, Part 200, et al), provides guidance to federal grantmaking agencies and applies to all federal awards received by Emerson College for research, scholarship, and other projects. The Uniform Guidance (UG) consolidated and replaced eight OMB Circulars such as the A-110 (Administrative requirements), A-21 (Cost principles), and A-133 (Audit requirements). Federal agencies (NIH, NSF, NEA, etc) have each developed their own agency-specific implementation plans for the Uniform Guidance.

What’s Changed

On November 12, 2020, OMB implemented its Final Guidance on amendments to the OMB Guidance for Grants and Agreements. Overall, these changes give agencies more flexibility in designing and monitoring programs, as well as encouraging the use of data collection and analysis to identify best practices.

Key Changes for Emerson and Principal Investigators (PI’s) on Federal Awards

• “Must” Vs. “Should.” Section §200.101(b)(1) clarifies that when the word “must” is used it indicates a requirement. Whereas, use of the word “should” or “may” indicates a best practice or recommended approach, and permits some discretion.
• SAM.Gov Registration. SAM.gov registration numbers will be replaced with the new Unique Entity Identifier (UEI), and current SAM registrants will receive a UEI automatically. The UEI transition timeline was recently be extended to April 2022. DUNS numbers will be phased out for new registrations. SAM will retain DUNS numbers for historical purposes.
• Subaward Reporting. The reporting threshold for subawards, under the Federal Funding Accountability and Transparency Act (FFATA), has increased from $25,000 to $30,000.
• Prohibition on Certain Telecommunications Equipment and Services. Federal funds may not be used to make purchases from Huawei Technologies Company or ZTE Corporation and their subsidiaries 
• Methods of Procurement. The micro-purchase threshold was raised from $3,500 to $10,000; the simplified acquisition threshold was raised from $150,000 to $250,000.
• Domestic Preferences for Procurements. Grantees are encouraged to maximize the use of goods, products, and materials produced in the United States when procuring goods and services under Federal awards.
• Monitoring and reporting program performance. Grant reporting requirements may become more stringent; granting agencies are required to more actively monitor progress on certain discretionary research awards.
• Termination. Granting agencies are given more latitude in terminating an award when it is not meeting “program goals” or “agency priorities.”
• Extended Closeout Dates. Final performance reports are now due 120 calendar days after the performance end date.
• Publication and Printing Costs. The New guidance clarifies that any printing and publishing costs may only be charged to a federal grant if the award is in its final budget period.

For an annotated breakdown of all the changes, check out the Council on Governmental Relations’ (COGR) Implementation and Readiness Guide for the OMB Uniform Guidance.