The document presents a series of detailed, advance questions directed at the Office of Management and Budget (OMB) concerning recent changes and updates to federal grant administration guidance, particularly with respect to cost principles, indirect costs, and award management. The queries reflect both constructive feedback and concerns from institutional stakeholders about the practical implications of revised regulations, such as threshold changes for Facilities & Administrative (F&A) cost rates, new requirements for the recognition of leave costs, and modifications to definitions and thresholds for equipment and modified total direct costs. The questions also probe the status of related implementation guidance and whether existing documents remain relevant following these updates.
Key issues raised include the operational impact and timing of new policies, the clarity and enforcement of guidance regarding indirect cost negotiations and subrecipient rate determinations, and the practical implications for institutional accounting and administrative systems. Stakeholders express concern about potential inconsistencies in federal agency requirements, particularly where agencies now appear to have broader discretion to grant exceptions, which could challenge the uniformity that the principles intend. Additional queries address the increased administrative burden and reduced flexibility associated with fixed-amount awards due to heightened compliance and documentation expectations. The document calls for further clarification from OMB, as well as ongoing collaboration between federal agencies and higher education representatives, to ensure that policy changes do not inadvertently hinder research performance or create inefficiencies in the use of federal funds.
