The document presents an in-depth overview of the Council on Governmental Relations' (COGR) initial analysis of the Office of Management and Budget (OMB) Uniform Guidance as of early 2014. The Uniform Guidance fundamentally reforms federal grant regulations by consolidating and streamlining administrative requirements, cost principles, and audit standards for federal awards. The COGR meeting, featuring expert presenters from major research universities, addressed critical changes and challenges in areas such as definitions, cost determinations, subrecipient monitoring, compensation, indirect (F&A) cost calculations, and internal controls. Notably, key changes include enhanced flexibility in compensation practices balanced by more rigorous internal control requirements, clarified definitions for materials (including computing devices as supplies), revised procurement thresholds, new risk assessment and reporting requirements for subrecipient monitoring, and modifications to F&A rate calculations and treatment of direct and indirect costs.
Throughout the presentation, COGR foregrounds the tension between the federal mandate to curb fraud, waste, and abuse and the increased data, metrics, and administrative burdens on institutions. The guidance emphasizes the importance of strong internal controls aligned with COSO standards, particularly in documenting personnel expenses and certifying financial reports. It also introduces important procedural updates, such as mandatory conflict-of-interest disclosures, certification attestation with strong legal language, adjustments to accounting for fringe benefits and depreciation, and new rules regarding cost sharing and administrative charges. While providing greater clarity and some flexibility, the Uniform Guidance imposes additional compliance responsibilities on recipient organizations, and the document underscores the need for ongoing institutional review, continued advocacy, and careful attention as federal agencies interpret and implement these regulations.
