OMB Uniform Guidance
On December 26, 2013, the Office of Management and Budget released the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance (UG) simplifies and supersedes guidance that was previously contained in eight different OMB Circulars, including A-110, A-21, and A-133. Contained within the UG are new definitions, uniform administrative requirements for both pre and post award, cost principles, and audit requirements. Federal agencies are currently developing their implementation plans under this guidance and these new regulations will become effective on December 26, 2014. The UG administrative requirements and cost principles will apply to new and incremental Federal funding awarded after December 26, 2014. It is important to note that existing Federal awards will continue to be governed by the terms and conditions under which they were awarded until amended. Further, subpart F, concerning audit requirements, will apply to audits of non-Federal entity fiscal years beginning on or after December 26, 2014. For WVU, this will be FY16 (July 1, 2015 – June 30, 2016).* Please note that Procurement mandates will not go into effect for 1 year.
The Office of Sponsored Programs (OSP) here at West Virginia University is committed to making the transition to new Uniform Guidance as seamless as possible for our research community. We, along with Financial Services and representatives from some of the EBO’s across campus are working diligently to make sure that the University and West Virginia University Research Corporation are ready to implement the new guidelines on December 26, 2014. Weekly meetings are being conducted to head off any confusion and existing University policies are being updated to fit new guidelines. OSP will update this page as new information becomes available from Federal agencies and OMB.
West Virginia University’s Uniform Guidance Quick Guide
Below are links made available to the public concerning the new guidelines:
OMB Policy Statements
- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards: Federal Awarding Agency Regulatory Implementation Published 12/19/2014
- Federal Awarding Agency Regulatory Implementation of Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards PDF 12/19/2014
- Major Policy Reform
- Subpart A: Definitions and Acronyms
- Subpart B: General Provisions
- Subpart C: Pre-Award Requirements
- Subpart D: Post-Award Requirements
- Subpart E: Cost Principles
- Subpart F:
* OMB Circular A-133
- COFAR FAQs Updated 8/29/2014
- COFAR Webinar on Uniform Guidance Implementation 10/2/2014
- Agency exceptions or additions to the Uniform Guidance
Resources for Understanding the Uniform Guidance
- COGR Guide Updated 9/17/2014
- COGR Readiness Guide 12/12/2014
Uniform Guidance videos from National Council of University Research Administrators (NCURA)
- NSF Comment Request and Responses Federal Register
- NSF Grants.gov Application Guide posted on 12/17/2014
- NSF Grant General Conditions (GC-1) 12/26/2014
- Proposal & Award Policies & Procedures Guide Webinar 1/27/2015
- National Science Foundation RTCs Agency Specific Requirements - Effective April 3, 2017
- Eye on NIH Policy: OMB Uniform Guidance 3/12/2015
- New Grants Policy Statement for 2015 3/31/2015
- NOT -OD-15-095 NIH Policy on Application Compliance – The purpose of this notice is to remind applicants, both investigators and grants office officials, that to be fair to all concerned the NIH needs to consistently apply standards for application compliance.
- Agency Specific Requirements for the National Institutes of Health (NIH) 4/2017
On March 14, 2017, The Office of Management and Budget published the final Research Terms and Conditions (RTC) to address the Uniform Guidance. Please see the Federal Register notice at https://www.gpo.gov/fdsys/pkg/FR-2017-03-14/html/2017-04955.htm for more information. To review the revised terms and conditions, please see the National Science Foundation (NSF) Awards Terms and Conditions page.
The Office of Management and Budget (OMB) has announced an extension of the grace period for non-Federal entities to implement the procurement standards included in Uniform Guidance. These entities are granted an additional year, meaning the implementation date for the procurement standards (2 CFR 200.317 through 200.326) will start for fiscal years beginning on or after December 26, 2017. Please see the Federal Register notice at https://www.gpo.gov/fdsys/pkg/FR-2017-05-17/html/2017-09909.htm for complete information.