The document summarizes the key discussions and outcomes from the COGR Uniform Guidance Panel held on October 22, 2020, focusing on significant revisions to the Uniform Guidance regulations (2 CFR) impacting research administration and compliance for federally funded awards. The panel, consisting of senior research administrators from prominent U.S. universities and COGR leadership, addressed changes in section numbering, new regulatory definitions, and clarified terminology (such as "must" vs. "should"), as well as updated requirements for institutional communication, compliance, and internal controls. Of particular note are updates regarding effective dates, enhanced statutory and national policy requirements, new provisions for System for Award Management (SAM) registration, and the implementation of the Unique Entity Identifier (UEI).
Key regulatory changes discussed include revised risk assessment procedures for subrecipient monitoring, permitting prime recipients to rely more broadly on subrecipients' Single Audit results, and greater flexibility regarding subrecipient indirect cost rates. Further adjustments include stricter prohibitions on contracting with certain foreign companies (e.g., Huawei), changes to procurement thresholds, reinforced reporting requirements, and extended closeout periods. The panel highlighted both benefits (such as clearer termination procedures, improved performance monitoring expectations, and rationalized closeout timelines) and unresolved areas needing further clarification, particularly regarding subaward management and the newly assigned responsibilities for pass-through entities to negotiate indirect cost rates for subrecipients lacking direct federal funding. The panel emphasized the need for effective institutional communication strategies and policy updates to ensure compliance and smooth implementation across campus stakeholders.
