[Okgrantsmanship] Teleconference Calls Re: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

[Mason, Linda]

Dear Colleagues,

The purpose of the issuance of the Uniform Guidance is to provide government that is more efficient, effective and transparent, the Office of Management and Budget (OMB) is streamlining the Federal government's guidance on Administrative Requirements, Cost Principles, and Audit Requirements for Federal awards.

Our phone call on May 20 about Uniform Guidance information was about 30 minutes in length on Tuesday, May . Participants included persons from Western, Seminole, NSU, CU, and LU.

A brief overview included:

*         Three main resources that may be useful to policy drafters include:

1)    The Crosswalk Document - http://www.whitehouse.gov/sites/default/files/omb/fedreg/2013/uniform-guidance-crosswalk-to-predominate-source- <http://www.whitehouse.gov/sites/default/files/omb/fedreg/2013/uniform-guidance-crosswalk-to-predominate-source-%20%0d%20%20%20%20%20%20%20%20existing-guidance.pdf>

        existing-guidance.pdf<http://www.whitehouse.gov/sites/default/files/omb/fedreg/2013/uniform-guidance-crosswalk-to-predominate-source-%20%0d%20%20%20%20%20%20%20%20existing-guidance.pdf>

1)      The Searchable Document - http://www.ecfr.gov/cgi-bin/text-idx?SID=e229aed322251eefcc78f38a08d91202&node=pt2.1.200&rgn=div5

2)      Posted Institutional Policies - OU at http://vpr.okstate.edu/; http://research.ouhsc.edu/forms-policies/; OSU at http://vpr.okstate.edu/, Harvard at http://osp.finance.harvard.edu/policies


*         Some main items of the required changes in written policy are the inclusion of:

1)   risk assessment,

2)    monitoring of subgrantees, and

3)    required staff and PI training.


*         I issued a July 1 deadline to submit a written and approved institutional grant policy to the Oklahoma State Regents for Higher Education. This deadline can be met by submitting a copy or access to the written/approved policy, but also institutions that do not have a written policy completed and approved by July 1 may act on the option of responding with a status statement. A status statement should provide an anticipated date of approval of an institutional grant policy.


*         One major change in the Uniform Guidance is that the granting agency will monitor subgrantees. This includes risk assessment, reporting, F&A overhead sharing with all subgrantees, and information transparency. (See 200.205 Federal awarding agency review of risk posed by applicants; 200.207 Specific conditions; 200.208 Certifications and representations; 200.301 Performance measurement; 200.302 Financial management; 200.324 Federal awarding agency or pass-through entity review; 200.327 Financial reporting; Monitoring and reporting program performance; 200.330 Subrecipient and contractor determinations; 200.331 Requirements for pass-through entities; 200.400 Policy guide.)



*         A written policy about the capability to make a risk assessment about potential grantees and subgrantees is part of the requirements of the Uniform Guidance. Risk assessment includes protection of human subjects, protection of animal subjects, conflict of interest, responsible conduct of research, certification regarding debarment and suspension, access to audit information, F&A rate negotiations, capability of cost sharing, export control, and fiscal responsibility. (See 200.205 Federal awarding agency review of risk posed by applicants; 200.302 Financial management; 200.303 Internal controls; 200.400 Policy guide; 200.419 Cost accounting standards and disclosure statement; 200.519 Criteria for Federal program risk)



*         Specific grant question: Dr. Goldie Thompson, Director of Teacher Education for OSRHE, and the director of the Elementary and Secondary Education Act (ESEA), Improving Teacher Quality Grant Program, issued a request for a statement of institutional internal controls for those institutions that received the ITQ grant this year. The statement of internal controls may be copied and sent if it is not online, an online url may be sent, or a person who represents access to information regarding institutional internal controls (such as a fiscal officer). The intent is to establish the capability for the OSRHE ITQ program to make a realistic risk assessment about the subgrant recipient, according to the Uniform Guidance regulations. In the future the OSRHE subgrant program officers will request a form insuring institutional data access to be used for risk assessment at the pre-award level. It will be a lot easier to respond to, in the same way that a form insuring a drug-free workplace and equal employment opportunity practices are maintained. I can answer specific questions about the ITQ request, and Dr. Thompson can answer specific questions, too. (See 200.303 Internal controls; 200.302 Financial management; 200.400 Policy guide.)



*         Required staff and PI training is needed in order to hold all the staff and PI's accountable for their administrative and fiscal actions. OSRHE will require all grant-related staff to attend annual training, and will provide additional consultative training as needed. OSRHE will require that all their subgrantees attend annual training, too. It is anticipated that the institutions will need to engage in annual training for their grant staff and PIs. (See 200.205 Federal awarding agency review of risk posed by applicants; 200.302 Financial management; 200.400 Policy guide.)



*         We discussed the State Regents' timeline, which is July 1 for our written document, August for submission to legal counsel, September for submission to presidents and provosts, and for public posting, and October for Regents' consideration and approval. The campus timeline may in fact be similar (not completed by July 1), but it will be shorter because institutions do not require the public posting of policy changes. As you can see from this timeline, we will not have a document approved by the beginning of the fiscal year, July 1. The actual functional deadline required by the issuance of the Uniform Guidance is the audits of the effective fiscal year after the UG effective date. (See 200.110 Effective/applicability date.)


*         Each week a telephone conversation via teleconference is provided with all who wish to participate from the higher education institutions and the Coordinator of Grantwriting for the Oklahoma State Regents. The dates and times are Tuesdays at 10:00 am. The length of the phone call will be approximately 30 minutes.

I look forward to talking with you next week and in subsequent weeks. I believe it is helpful to hear other institutional questions and the answers provided. It helps to understand better when you hear FAQs from other perspectives.
Scheduled Calls
Wednesday, May 27 - 10:00 am-10:30 am
Wednesday, June 3 - 10:00 am-10:30 am
Wednesday, June 10 - 10:00 am-10:30 am

The maximum number that can be on a call is 27. If we decide that our response is too many, we could break up the plan into two times instead of one to reduce the number of people on one call. Just call 405-225-9100 and ask to be put into the Uniform Guidance or Grant teleconference with Dr. Mason.


Dr. Linda Mason
Coordinator of Grant Writing
Oklahoma State Regents for Higher Education
655 Research Parkway, Suite 200
Oklahoma City, OK 73104
405-225-9486 desk
405-706-8757 cell
405-225-9230 FAX
lmason at osrhe.edu<mailto:lmason at osrhe.edu>
www.okhighered.org/grant-opps/<http://www.okhighered.org/grant-opps/>


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