5 Things PIs Need to Know About Uniform Guidance

In case you haven’t heard, the federal government is implementing new Uniform Guidance standards for grants on December 26th.

Merry Christmas! 😀

All sorts of myths and misconceptions about the “UG” is now floating around as the day looms near. (And yes, I have been referring to the new guidance as “UG,” followed by a heavy sigh!) So, what can we really expect from these new regulations?

Well, despite my sarcastic parenthetical above, I am pleased to report that these standards will actually make research administration easier! (I think) With the exception of a new rule, taking effect July 2016, mandating bids for purchases above $3,000, the changes will probably make your job a LOT easier. The UG seeks to clarify and standardize regulations across agencies.

So, what are the five hottest topics related to the upcoming UG? Take some time to review this list, and then check with your friendly research administrator to see how your university will be implementing them. (Just as a disclaimer: I am not going to broach the subject of the new bidding requirements – it’s too far off, too much might change – and, okay, okay, you got me – it’s WAY too scary a topic!! 😀 )

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• The cost of child care can now be added to travel expenses! But…the cost is only allowable if your university includes child care in their travel guidelines. If your institution does not typically allow child care costs, sorry, you are out of luck!
• You can now purchase computers as part of your project costs – even if they are not 100% allocable to the project! But…the computer in question still needs to be “integral” to the project. What does “integral” mean? We probably won’t know for sure until the UG has been implemented. But, safe to say, the computer should be important to the project and the price tag should be reasonable.

• Cost-sharing is now not allowed across the board. But…some projects may still require it. Still, the UG will (in theory) forever remove the consternating sentence: “Cost share is recommended” from RFPs. So, cost-sharing will either be “not required” (typical) and “required” (rare).
• Subaward monitoring will now be standardized. But…that doesn’t necessarily mean it will get easier! Currently, a PI can usually keep track of PIs at other institutions simply by approving invoices and asking for more information on a request-by-request basis. Now, technical reports will be required for invoice approval. While this might be more time-consuming for PIs, it will also mitigate subawardee problems before they start…in theory, anyway
• Administrative staff can now be added to projects. But…they must be “integral” to the work being done for the project (there’s that word again!). Also, the administrative personnel cannot be paid for with recovered F&A costs. In other words, no double-dipping!