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Wayne State University

Aim Higher

Jan 30 / RAS

COFAR, So Good

Now that Uniform Guidance (2 CFR 200) has been in place for a good, solid month and proposal deadlines are looming large, here are few highlights to changes from the way things were previously done:

 

  • Administrative salaries [§200.413 (c)]They’re now allowable, even for non-“major projects,” as long as the cost is “integral” (read: the services are essential, vital, or fundamental to the project or activity)
  • Computing Devices [§200.343]These are now considered a “supply” when less than $5,000. They must be “essential and allocable,” but not necessarily solely dedicated, to the performance of a federal award
    • If the device is NOT solely dedicated, you must justify its use in the project and allocate costs appropriately
  • Cost sharing [§200.306 (a)]: Cost sharing (matching, not inclusive of over-the-cap salary payment) cannot be used during the merit review of proposals, unless specified in a notice of funding opportunity
  • PD/PI Disengagement [§200.308]: Prior approval is required for the disengagement of a PD/PI for more than three months, or a 25 percent reduction in time devoted to the project; project directors can be away from campus and remain engaged in the project at the proposed and awarded levels
    • The difference here is the term “disengagement” rather than “absence;” this recognizes that a PI/PD can be off campus and still engaged in the research, which would not require prior written approval
  • Publication Costs [§200.461 (3)]: Anticipated publication charges that will occur outside of the period of performance CAN be charged
  • Subawards [§200.332]: Fixed price subawards require prior approval and limit each subaward to $150,000

 

If you have any questions about how these changes may affect your award or your proposal, let us know.  We’re here to answer any questions you may have in developing your budget or award strategy!