What is Uniform Guidance?
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) were released on December 26, 2013. The Uniform Guidance streamlines and supersedes guidance that was previously contained in eight different OMB Circulars. Included in the new guidance are definitions, uniform administrative requirements (both pre- and post- award), cost-principles, and audit requirements. From the university perspective, the Uniform Guidance will supplant OMB Circulars A-110, A-21, and A-133 as the definitive resource for administrative issues.
When is Uniform Guidance in effect?
The Uniform Guidance administrative requirements and cost-principles will apply to new and incremental funding awarded after December 26, 2014. Existing Federal awards will continue to be governed by the terms and conditions under which they were awarded.
Subpart F, Audit Requirements, will apply to audits on non-Federal entity fiscal years beginning on or after December 26, 2014. For Wayne State University, this will be Fiscal Year October 1, 2015 – September 30, 2016.
Where can I find more information?
The Council on Governmental Relations (COGR) has done extensive work to analyze the guidance, and a link to its “COGR Guide” document is provided (see Related Links). The Federal Demonstration Partnership (FDP) has done analysis and partnered with COGR to produce white papers on various Uniform Guidance topics (see Related Links).
Additional information regarding Uniform Guidance is available at the Council on Financial Assistance Reform (COFAR) website, which contains background information, FAQs, and links to the Uniform Guidance and supplemental materials.
How is WSU implementing the Uniform Guidance?
Wayne State University is working as part of the Council on Governmental Relations and the Federal Demonstration Partnership to analyze and understand the potential impacts of the Uniform Guidance. Wayne State University is awaiting Federal agencies’ final implementing guidance. Federal agencies were to submit draft implementing guidance to the Office of Management and Budget by June 26, 2014 and are expected to implement the requirements by December 26, 2014. In the interim, Sponsored Program Administration is working with WSU Fiscal Operations to identify the major areas of impact. Implementation plans are underway and will be communicated to the various stakeholders as they become available.
For questions or comments related to Uniform Guidance or WSU‘s implementation of Uniform Guidance, please contact Gail Ryan, Assistant Vice President, Sponsored Program Administration,firstname.lastname@example.org; 577-6595.
Known Issues with NIH Multi-project Applications & Dealing with System Issues
There are a couple of known software issues impacting electronic multi-project applications that we’d like to bring to your attention…
Character Limitation for Project Titles of Components
We are currently unable to process applications where the ‘Descriptive Title of Applicant’s Project’ field on the SF424 (R&R) cover form used within multi-project application components is over 75 characters. Although you can use up to 200 characters for your main project title in the Overall component, you can only use 75 characters for the project titles of all other components. This limitation is the result of an issue with how we are generating the Table of Contents within our multi-project assembled application images.
If you are using ASSIST, then this issue may also impact your ability to successfully generate an application preview. If your attempt to generate a preview results in a ‘Failed’ status, check the length of each component project title before trying again.
The fix to this issue will be available on August 8, 2014. Until then, please limit the project titles of your components (other than Overall) to 75 characters or less.
This issue does not impact single-project applications (i.e., you can still include project titles up to 200 characters for your R01 and other single-project submissions.)
Multiple Editors and the Delete Application Action in ASSIST
One of the nice features of ASSIST is that you can have multiple people simultaneously working on your application. However, this also poses some challenges from a system’s perspective. When implementing the new Delete Application feature, we did not correctly handle the scenario when one user attempts to delete an application when another user is editing it.
Currently, the system is working like this…Mary is editing a form in the application. John attempts to execute the Delete Application action, but receives an error indicating that a form in the application is locked by Mary. Mary gets out of the form so John can delete the application. On John’s subsequent attempt to delete the application, he still receives a message indicating that the form is locked by Mary. John must log out of ASSIST and log back in in order to complete the action without errors.
We are scheduled to release a fix to this issue on October 17, 2014. This tiny glitch shouldn’t cause too much worry in the meantime since it only impacts applications that you want to delete.
What to do if you encounter a ‘System Issue’
Experiencing a system issue with ASSIST, Grants.gov, SAM, or eRA Commons that you believe threaten your ability to submit on time? Don’t panic. NIH will not penalize applicants who experience confirmed system issues that are beyond their control. However, it is imperative that you follow our Guidelines for Applicants Experiencing System Issues. This process includes contacting the eRA Commons Help Desk by the due date to report your issue and your good-faith effort to submit on-time. Once it is confirmed that a system issue exists, the help desk will work with you to determine the best path forward. In many cases, the eRA production support team can reprocess your application without any additional action on your end. In other cases, they will provide guidance on changes that must be made to the application in order to process it. Either way, the first step to resolution is contacting the eRA Commons Help Desk.
Applicants that fail to document their issues on or before the submission deadline or that do not have a confirmed system issue will be subject to the standard NIH Policy on Late Submission of Grant Applications.
As always, the eRA Commons Help Desk is available to clarify any of the above items.
Your day is most likely filled with constant communication. Weblog Mind Tools (via Lifehacker) offers a communication checklist to help ensure that your emails, phone calls, and meetings are always productive.
According to the 7 Cs, your communication should always be:
- Clear: Make the goal of your message clear to your recipient. Ask yourself what the purpose of your communication is.
- Concise: Your message should also be brief and to the point. Why communicate your message in six sentences when you can do it in three?
- Concrete: Ensure your message has important details and facts, but that nothing deters the focus of your message.
- Correct: Make sure what you’re writing or saying is accurate. Bad information doesn’t help anybody. Also make sure that your message is typo free.
- Coherent: Does your message make sense? Check to see that all of your points are relevant and that everything is consistent with the tone and flow or your text.
- Complete: Your message is complete when all relevant information is included in an understandable manner and there is a clear “call to action”. Does your audience know what you want them to do?
- Courteous: Ensure that your communication is friendly, open, and honest, regardless of what the message is about. Be empathetic and avoid passive-aggressive tones.
Think about the 7 Cs every time you need to communicate something and you’ll always know you’re delivering the clearest message possible.
“If you drop a computer on your toe, you will have megahertz.”
Dear Dr. Llama,
I am nearing the end of my project and need to purchase a computer and the Sponsored Programs office is giving me grief about this. I’ve got my eye on this sharp new Macintosh and want to get it. Now. Any advice?
Dr. Jona Licious
Dear Dr. Licious,
Computer purchases in the final months of a project period raise audit concerns. What is the benefit to the sponsored project? Obtain documentation and keep for audit purposes. All charges to a project, particularly in the last 90 days of the project period, must be allowable and allocable as a direct cost, and be reasonable and necessary for the conduct of remaining project activities. If the computer is expected to be used beyond the project expiration date, the cost should not be allocated 100% to the expiring project unless continuation funding from that same sponsor is expected.
And remember, purchases to just use remaining funds at the end of a project are not appropriate!
The National Defense Authorization Act, P.L. 112-239 (PDF) (NDAA) established a pilot program for the enhancement of contractor and subcontractor employee protections from reprisal for whistleblowing.
What is Whistleblowing?
Whistleblowing is the disclosure by a person, usually an employee in a government agency or private enterprise, to the public or to those in authority, of mismanagement, corruption, illegality, or some other wrongdoing. Specifically:
- Gross mismanagement of a Federal contract or grant;
- The gross waste of Federal funds;
- An abuse of authority relating to a Federal contract or grant;
- A substantial and specific danger to public health or safety; or,
- A violation of law or regulation related to a Federal contract or grant (including the competition for, or negotiation of, a contract or grant).
Section 828(a) of the NDAA, Pilot Program for Enhancement of Contractor Employee Whistleblower Protections, provides that, “An employee of a contractor, subcontractor, or grantee may not be discharged, demoted, or otherwise discriminated against as a reprisal for disclosing the aforementioned types of information to:
- A Member of Congress, or a representative of a Congressional committee,
- An Inspector General,
- The Government Accountability Office,
- A federal employee responsible for contract or grant oversight or management at the relevant agency,
- An official from the Department of Justice, or other law enforcement agency,
- A court or grand jury, or,
- A management official or other employee of the contractor, subcontractor, grantee, or sub-grantee who has the responsibility to investigate, discover or address misconduct
The pilot program also establishes a new process for review of whistleblower reprisal complaints alleged by employees of contractors, subcontractors, and grantees, “A person who believes that the person has been subjected to a reprisal prohibited by subsection (a) may submit a complaint to the Inspector General of the executive agency involved.”
Procedures for submitting fraud, waste, abuse, and whistleblower complaints are generally accessible on the Office of Inspector General (OIG) website, via phone (800) 409-9926, or Whistleblower Internet sites, such as these:
- Department of Agriculture : http://www.usda.gov/oig/contractorform.htm
- Department of Health and Human Services: https://forms.oig.hhs.gov/hotlineoperations/
- National Institutes of Health: http://oma.od.nih.gov/public/DPI/Pages/default.aspx
- National Science Foundation: http://www.nsf.gov/oig/
Concerns related to alleged fraud, waste, and/or abuse may be reported anonymously to the Wayne State University Office of Internal Audit as follows:
- Online Tips Form – www.internalaudit.wayne.edu
- Hotline – (313) 577-5138
All allegations will be investigated and reported to the appropriate University officials and the sponsor. Please provide sufficient information to enable a thorough investigation.