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Faculty Announcement on Uniform Guidance

Posted Date: 12/31/2014 10:14 AM

Content Categories: Federal Regulatory News; Policies-Guidelines-Procedures\NIH; Policies-Guidelines-Procedures\NSF; Policies-Guidelines-Procedures\Other Federal Agencies

Subject: Faculty Announcement on Uniform Guidance

Faculty Announcement – Uniform Guidance

​December 31, 2014

New Federal Rules for Grants – Do they change the way I manage my grants?

The federal government recently issued new rules for federal grants. The new rules took effect on
December 26, 2014. It is important to note that many of the federal agencies that sponsor research activities have not yet issued their implementation of the new federal rules. This is the first in a series of short announcements that will highlight what you, as the PI, need to be aware of as you manage your proposals and awards under the new rules.

It is important for you to know that we are communicating many of the details regarding these changes to your school, department or program administrator.

1. Criteria used to justify direct charging of administrative/clerical costs have been revised
​​​​​Administrative and clerical salaries may be appropriate as direct charges when all of the following conditions are met:

    • Administrative or clerical services are integral* to a project or activity;
    • Individuals involved can be specifically identified with the project or activity;
    • Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
    • The costs are not also recovered as indirect costs.

*Budget justification should explain how administrative/clerical costs are “integral” to the project. While this is not a significant change from our previous WU practices, we do recommend that you incorporate this language into your proposals: “We consider [List position title here] an administrative cost allowed under 2 CRF 200.413. In the event this proposal is awarded, we will consider the award document sufficient agency approval for this administrative cost.”

2. New de minimis​ F&A cost rate for subrecipients that do not have a federally negotiated rate.

When including a subrecipient’s budget in a WU proposal, you must now use the subrecipient’s negotiated F&A rate. If the institution does not have a negotiated rate, your subreciepient budget should include an F&A rate of no less than 10%. If the sponsor has a cap, the capped rate must be used by WU and the subrecipient.

3. Subaward may be issued as a fixed- price subaward if the total value is $150,000 or less, and meets specific criteria; agency prior approval is required.

Please include the following statement in the budget justification for any subaward that you intend to be a fixed- price subaward: “This proposed subaward meets the requirements in Uniform Guidance, subpart C-200.201(b) and will be issued as a fixed price subaward. Inclusion of the proposed intent to issue a fixed price subaward and the subsequent award by agency will be considered prior agency approval.”

4. Computing device purchases are allowable under specific circumstances.

You may include computing devices (<$5,000) itemized in “materials and supplies” in the proposal budget and you should describe these costs in the budget justification (or in the case of NIH Modular Grant applications, itemized in the WUSTL PDS doc).

Note: Computer purchases are subject to university policy and approval by SPA. A justification will still be required on each transaction.

Should you have any questions or concerns, please contact Christa Johnson, christajohnson@wustl.edu, or Joe Gindhart, jgindhart@wustl.edu.


This information was authored by Danica Johnson  

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