The referenced document outlines a comprehensive update on the Uniform Guidance revisions by COGR as part of its ongoing “Look” Series, culminating in a session held on October 24, 2024. Led by key COGR directors and supported by a diverse workgroup from prominent research institutions, the presentation reviews the progression of COGR’s analyses—starting from initial assessments and member feedback to in-depth webinars, direct engagement with technical corrections, and readiness guidance. Major elements under discussion include substantial changes to 2 CFR 200, such as increased thresholds for equipment purchases, subawards, single audits, updated F&A (Facilities and Administrative) cost rates, and new requirements for fixed amount awards. The session also captures institutional responses gathered via advance polling, highlighting a broad spectrum of preparedness, approaches to implementation, and concerns regarding regulatory clarity and operational impacts. The presentation delves into practical challenges institutions face with implementing the Uniform Guidance revisions, referencing issues such as compensation and fringe benefit charging, the phasing out of DS-2 (Disclosure Statement) requirements, and timing mismatches between federal and institutional fiscal years. Discussion further extends to the implications for fixed amount awards, with audience polls revealing varying degrees of impact and institutional readiness. Attendee questions underscore a need for agency-level guidance, clarity on reporting and compliance requirements, and operational tools such as templates for comparison and documentation. Overall, the session emphasizes COGR’s ongoing commitment to supporting its members through regulatory change by facilitating dialogue, aggregating collective concerns, and promoting informed, collaborative adaptation across the research administration community.
