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Uniform Guidance: Budgeting Considerations

The Uniform Guidance (UG) 2 CFR 200 issued by the White House Office of Management and Budget (OMB) includes revised cost principles for federal awards made on or after December 26, 2014.

Below is a reminder about a few cost items that need attention when preparing proposal budgets under the new Uniform Guidance.

1) Budgeting Administrative and Clerical Salaries as a Direct Cost

UG Sections 200.413, 200.430

The Uniform Guidance clearly states salaries of administrative and clerical staff should normally be treated as indirect (F&A) costs however, direct charging of administration and clerical costs may be appropriate to a federal award only if all of the following conditions are met:

  • Administrative or clerical services are integral❶ to a project or activity;
  • Individuals involved can be specifically identified with the project or activity;
  • Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and
  • The costs are not also recovered as indirect costs.

❶UF considers integral to mean: (1) circumstances exist where administrative or clerical services being provided are necessary for the performance of the project or activity being supported by the federal award; AND (2) a minimum of 20% FTE is budgeted in the grant’s budget year or if less than 20% FTE special circumstances are documented and approved by the Sponsor.

Budgeting: If you believe your project meets all the conditions above, you must specifically budget for the effort and salary of the administrative or clerical position that will be devoted to the project and provide in the budget justification a narrative that explains how these administrative and clerical services are integral or necessary for the performance of the project or activity.

CAS Exemption Needed: If awarded, UF will require a CAS exemption form be completed, reviewed, and approved for administrative and clerical salaries to be direct charged to federally funded projects.

2) Budgeting for Computing Devices as a Direct Cost

UG Sections 200.453 (c)

The Uniform Guidance allows the direct charging of computing devices, costing less than$5,000 as a material and supply cost provided they are essential ❷ and allocable to the project. Computing devices do not have to be solely dedicated to the performance of a federal award, in order to be charged 100% to a single award or allocated to several awards. Computer devices are expected to be primarily used to support the performance of the federal award.

❷ UF considers essential to mean: Computer devices and accessories that are necessary for the performance of the project or activity being supported by the federal award. Examples of essential, might include: (1) used to acquire, store, analyze, process, and publish data necessary for the performance of the project or activity; (2) used to create information electronically, including printing, transmitting, receiving and visualizing the information in support of the performance of the project or activity; (3) used in training, instruction, or curriculum development activities funded by the federal award; or (4) other circumstances demonstrated as essential.

Budgeting: If you believe computer devices and/or accessories are essential and allocable to the performance of your project and meets the conditions above, you should budget for the computer devices and/or accessories and provide in the budget justification a narrative that explains how the items are essential to the performance of the project.

In the case of NIH Modular Grant applications, computing devices and/or accessories should be itemized and justified in the detailed budget provided to UF.

CAS Exemption Needed: If awarded, UF will require a CAS exemption form be completed, reviewed, and approved for any computer devices and accessories costing less than $5,000, budgeted or not.  Budgets that include computer devices and/or accessories that have been justified as essential will assist and expedite the CAS Exemption request.

3) Budgeting for Fixed Price outgoing Subawards

UG Sections 200.201, 200.332

Federal sponsor prior approval will be required in order for UF to issue a fixed price subaward rather than a cost-reimbursement subaward.   The total cost of each fixed price subaward may not exceed $150,000.

Budgeting: UF typically uses fixed price subawards with foreign subrecipients, clinical trial site agreements and occasionally with small businesses or organizations. To expedite sponsor approval, Investigators who are contemplating a fixed price subaward must include the following or similar statement in the budget narrative:

“The budgeted subaward for (Insert Subrecipient name) will be issued as a fixed price subaward. The University of Florida will consider this fixed price subaward approved if the award is made and no contrary guidance has been provided by the Sponsor to the University in the award notice.”

Need Assistance: If you need assistance in determining whether the anticipated subaward would be issued as a fixed-price subaward or cost-reimbursable, please contact ufproposals@ufl.edu.

For Clinical Trials, please contact RAC.

At time of Award:  UF will work with the PI and department to determine whether a fixed price or cost-reimbursement subaward is appropriate. UF will make the final determination whether to use a fixed price or cost-reimbursement subaward regardless of whether a fixed price statement was included in the proposal. If the fixed price subaward statement was missing in the budget narrative and a fixed price subaward is deemed most appropriate, UF will assist in generating the request for sponsor approval.

F&A Budgeted for Subawards

UG sections 200.331, 200.414

Under the Uniform Guidance, Facilities & Administrative (F&A) costs should be budgeted for subrecipients as follows:

Budgeting: If the subrecipient has a federally negotiated F&A rate, the negotiated rate must be included in all proposed subawards. If the subrecipient does not have a federally negotiated F&A rate, under the Uniform Guidance “may elect to charge a de minimis rate of 10% of modified total direct costs (MTDC) which may be used indefinitely.”

Questions:

If you have any questions, please contact UF at ufproposals@ufl.edu.

4) Resources

The Federal Guidance

Council on Governmental Relations (COGR)

Videos from the National Council of University Research Administrators