Super Circular, Super Fun
It’s been around for nearly six months now, but the OMB Super Circular (also known as the “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, Final Rule”, and “Mega Circular”) is receiving some more attention as opportunities for its application increase. Many of you who attended the most recent SPA meeting most likely received a copy of the Huron Group’s chart, “Assessing the OMB Uniform Guidance: Major Changes and Impacts.” If you did not, it is available here and offers helpful visual reference as to how your strategies may change. Some of the highlights include:
Length of Opportunity: The guidance indicates that RFAs and PAs have to be available 60 days before the opportunity closes.
Accountability – Performance vs. Compliance: Results and outcomes that can be shared with other award recipients have strong emphasis in the new guidance. Noncompliance is not merely overlooked, of course; but the government ostensibly does not wish to create oppressive rules that prevent an investigator or a collaborating team from attaining their research aims. As you read the guidance, you’ll see that this is the goal.
Administrative Costs as Direct Costs: Specific information is given on how to manage administrative costs as a direct cost. Administrative costs are usually charged as indirects, so this can be tricky. If you’re unsure on how to do this, please contact RAS and we’ll help you figure out how you should be charging your admin costs.
Increasing Minimal Threshold for Indirect Costs to 10%: Organizations that cannot afford to negotiate an indirect rate can budget a 10% de minimis indirect rate with the federal government (as opposed to the previous rate of 8%).
Payment Management : The super circular provides new information on maintaining consistency in cost allocation, and at what point you need written approval for assigning a cost to an award. The cost principles and audit sections assert that there is now a limit of three years for the federal government to review awards in order to disallow costs. There is also a new 90 day rule for reporting on awards at the end of the project period. Taken together, there is much latent encouragement to spend your money before it is taken back.
Family-Friendly Policies: The new guidance encourages federally-funded organizations to implement family-friendly policies, including family-friendly issues such as costs related to the identification of day-care providers, and allowance of parents to document out-of-workforce time on biosketches.