The document summarizes a midterm assessment of the implementation of the Uniform Guidance (UG) as discussed during the June 2015 COGR meeting. Panelists from prominent research institutions provided updates on timelines, logistics, and emerging challenges related to the adoption and operationalization of the Office of Management and Budget’s (OMB) uniform standards across federal agencies. The presentation details key milestones, such as the publication and technical updates of the Uniform Guidance, agency-specific implementations, and ongoing opportunities for public comment. Particular attention is given to procurement standards, including the challenges associated with micro-purchase thresholds and competitive bidding processes, highlighting the operational impact on research institutions—such as the potential for increased administrative burden and staffing needs—using institutional case studies and data-driven analyses.
Additionally, the document addresses conflict of interest (COI) policies, noting significant variability in agency interpretations and requirements that undermine UG’s goal of uniformity, increase institutional compliance burdens, and complicate both policy application and training. Further, the report discusses agency deviations from specific UG provisions, particularly cost-sharing expectations, and suggests strategies for documenting, troubleshooting, and advocating for clarity and alignment with federal rules. Calls for harmonization of policies, clearer definitions, and transparent agency communications are recurrent themes, reflecting both achievements and remaining obstacles in the UG rollout. The presentation ends with a self-assessment prompt, indicating a cautious and critical outlook on the Uniform Guidance’s progress at this midpoint, with concerns over administrative burden, consistency, and the need for continued engagement and improvement.
