As you are probably aware, the Uniform Guidance (also referred to as A-81) went into effect on December 26, 2014. The Uniform Guidance was issued by the Office of Management and Budget (OMB) and was intended to streamline the administration and operation of federal awards while increasing the government’s oversight. The Uniform Guidance replaced eight different circulars, including A-21 – Cost Principles for Educational Institutions. The Uniform Guidance does not change the core principles of what costs can be charged to a federal award. Costs still must be necessary, reasonable, allocable, allowable and consistently treated. However, certain changes have been made in specific areas, including:
- Charging of administrative/clerical salary costs;
- Charging of computing devices under $5,000;
- Treatment of participant support costs;
- Treatment of visa costs; and
- Subawards, including a de minimum of 10 percent F&A.
For more information on these changes, please review the A-81 (Uniform Guidance) Quick Guide posted on the Office of Research website: https://research.usc.edu/files/2011/07/A-81-Quick-Guide-2.20.15.doc.
You may also review presentations from recent Research Administrators Forums on this topic. An overview on implementation was presented at the November 4, 2014 meeting and changes to the treatment of subawards was covered in the March 31, 2015 Forum: http://ooc.usc.edu/research-administrators-forum.