[Okgrantsmanship] OMB Final Guidance - Initial Comments from COGR

[Mason, Linda]

From: COGR <cogr at usc.edu<mailto:cogr at usc.edu>>
Date: December 19, 2013 at 11:20:56 AM CST
To: COGR Email List <cogr-list at mizar.usc.edu<mailto:cogr-list at mizar.usc.edu>>
Subject: OMB Final Guidance - Initial Comments from COGR

Last night COGR shared a “Dear Colleagues” letter, from OMB, announcing the release of the OMB Final Guidance, known also as A-81 or the Omni-Circular.  Below are initial COGR comments.  We will provide regular updates and insights over the coming weeks and months.
1) The Final Guidance will be published in the Federal Register on December 26th.  However, you can access it now on the federal “public inspection” list per the link below:
https://s3.amazonaws.com/public-inspection.federalregister.gov/2013-30465.pdf

2) The “public inspection” version is 758 pages.  The first 120 pages are a preamble that summarizes the Final Guidance.  The actual guidance begins on page 121.  The version to be posted on December 26th, most likely, will have less pages due to a different type set and format style.
3) We encourage you to join the OMB/COFAR webcast scheduled for tomorrow, Friday, December 20th, at 11:45 am.  Per OMB, Please visit www.cfo.gov/cofar<http://www.cfo.gov/cofar> (which will be updated after publication tomorrow) for more information and to register for the webcast.  Questions may be submitted to COFAR at omb.eop.gov<mailto:COFAR at omb.eop.gov>

4) The guidance is labeled as “Final Guidance”.  In the COGR Update that you received yesterday, we anticipated that the guidance would be “Interim Final Guidance”, which would have allowed one more opportunity to comment.  As “Final Guidance”, this is not the case.  However, we expect (hope) to have opportunities to address concerns with OMB and other federal officials prior to the effective date.

5) Per pages 36-37, the “Effective Date” will  be:  “… one year from the publication of this final guidance … this guidance will be in effect for all Federal awards of funding increments after the effective date.”   In other words, based on a December 26, 2013 Federal Register publication date, the Final Guidance will be effective on December 26, 2014.  Also note per page 37, “The COFAR further recommended that provisions of Subpart F - Audit Requirements be effective for non-Federal entity fiscal years beginning on or after the effective date of this guidance.”  For many institutions, this will result in the audit requirements becoming effective for the fiscal year July 1, 2015 – June 30, 2016.

6) COGR will provide regular updates, analysis, assessments, etc. over the coming weeks and months.  The February 27-28 COGR Meeting will be focused on the Final Guidance and we already have commitments from a number of Federal officials to participate in the February 27-28 COGR Meeting.

As always, we will appreciate your comments and observations as you dive into the detail of the Final Guidance.

David Kennedy
Director, Cost Policy - COGR
1200 New York Ave. NW, #750
Washington, DC  20005
(202) 289-6655, ext. 112
dkennedy at cogr.edu<mailto:dkennedy at cogr.edu>