The February 2013 COGR meeting presentation by Cynthia Hope and James Luther provided an in-depth analysis of the proposed Office of Management and Budget (OMB) Uniform Guidance Cost Principles, with a particular focus on Subchapter F. The presenters outlined the enduring themes of allocability, reasonableness, and consistency in cost principles, while noting persistent terminology inconsistencies across funding mechanisms and institution types. The session highlighted both advantageous changes—such as clearer treatment of non-capital computers as direct charges, new allowances for dependent care travel costs, and improved provisions around administrative personnel and meetings—and areas of concern or ambiguity, particularly with respect to unclear applications for contracts and evolving definitions for compensation and equipment.
Attendees were informed about eliminations and modifications regarding student roles in sponsored research, administrative costs, and requirements around indirect cost rates, as well as new provisions on compensation standards, payroll documentation, and equipment cost assignment. The presentation flagged issues needing further clarification, such as the definition of workload, requirements for full disclosure and internal evaluation, and the practical implications of documentation for compensation and indirect cost rates. While the guidance introduced beneficial simplifications—like the potential four-year extension of rates and streamlined documentation requirements—it also eliminated prior cost allocation rules and mechanisms for supporting depreciation reimbursement. Overall, the presentation served as both a guide and a caution, recognizing improvements in clarity and consistency but underscoring areas where the full impact and implementation details of the proposed guidance remained uncertain.
