The document is a presentation by Lynn McGinley delivered at a COGR Meeting in March 2015, focusing on the implications of the Uniform Guidance on Facilities and Administrative (F&A) costs and the related compliance requirements for institutions of higher education (IHEs). Key topics discussed include the definition of instruction and departmental research under NIH (PHS) guidelines, with attention to which salary costs and cost sharing must be included in the organized research base for indirect cost calculations. Changes surrounding Participant Support Costs and their exclusion from the F&A base are also highlighted, along with questions about the consistency of new definitions and implementation across sponsoring agencies.
Another significant topic is the Cost Accounting Standards (CAS) Disclosure Statement (DS-2), where the document addresses concerns regarding its practicality and enforcement, particularly the administrative burdens on IHEs and federal agencies. COGR’s proposals for revising submission timing and approval processes are detailed, advocating for greater flexibility and immediacy in allowing institutions to implement Uniform Guidance-related changes without extensive advance notice or approval requirements. The document also addresses fringe benefits, clarifying the allowability of tuition remission for employees and new provisions regarding tuition waivers. Lastly, the presentation touches on institutional reporting regarding changes in space and resource utilization since previous F&A proposals, suggesting ongoing feedback and evaluation within the university community and with federal agencies.
