The document is a formal letter from the Council on Governmental Relations (COGR), an association representing major research universities, addressed to Mr. Gilbert Tran at the White House Office of Management and Budget’s Office of Federal Financial Management. Dated August 26, 2016, the letter provides a set of proposed Frequently Asked Questions (FAQs) intended to clarify sections of the Uniform Guidance, a set of federal regulations governing the administration of federal grants and agreements. The letter emphasizes that the intention of these FAQs is to offer clarifying statements rather than create new policies, while acknowledging the nuanced distinction between clarification and policy interpretation.
The proposed FAQs address several key aspects of the Uniform Guidance, including procedures for audit reliance and monitoring of subrecipients, options for applying indirect cost rates and the use of the 10% de minimis rate, requirements for public advertisement of procurements, the process for instituting changes in institutional cost accounting practices, treatment of foreign subrecipients in audit requirements, responses to delayed federal management decisions, and the method for updating the Utility Cost Adjustment. Each FAQ is designed to reduce administrative burden, promote collaboration between federal agencies and research institutions, and clarify obligations under the current guidance. The letter concludes by expressing appreciation for ongoing dialogue with federal officials and a willingness to further support the clarification and technical correction of the Uniform Guidance.
