The Council on Governmental Relations (COGR) provided a summary of a conference call held on March 20, 2015, focusing on key developments and next steps for the implementation of the Uniform Guidance in partnership with the Office of Management and Budget (OMB), the Council on Financial Assistance Reform (COFAR), and other federal agencies. The document outlines clarifications and proposed actions regarding eight primary topics. These include confirming the scope of conflict of interest policies, advocating for audit/management decision safe harbors for peer institutions, recommending adjustments to procurement standards and thresholds, and proposing a standardized 120-day closeout period for all agencies. The summary also addresses the need for streamlined processes for DS-2 approvals, technical corrections to compensation and fringe benefit policies—particularly tuition reimbursement—and fairer policies for implementing the Utility Cost Adjustment.
Additionally, the document highlights challenges posed by staggered effective dates of the Uniform Guidance, as some awards continue under legacy circulars while others are subject to the new requirements. To address this, COGR suggests adopting an "institution-defined effective date" for transitioning policies and procedures, a measure they are recommending to OMB to facilitate smoother compliance and audit processes. The Council seeks affirmation and feedback on these positions from federal partners and stakeholders and emphasizes ongoing collaboration to ensure efficient and equitable implementation of federal regulations across research and academic institutions.
