Uniform Guidance Agency Implementation Cheat Sheet

Uniform Guidance Agency Implementation Cheat Sheet
Agency information is added/updated as it becomes available to the UW. Updated: 6 May 2015
The following chart provides information on how to determine if a federal award is subject to either the Uniform Guidance (UG) or the A-21/A-110
Circulars. Award documents rarely reference either of these documents, users instead must recognize either the Agencies specific terms and condition
documents or their Code of Federal Regulation (CFR) reference.
Agency
NIH
Uniform Guidance Reference
(2 CFR 200)
A-21/A-110 Circular Reference (all
dated prior to 12/26/2014)
45 CFR Part 75
45 CFR Part 74
http://www.ecfr.gov/cgibin/textidx?SID=5d0286bc94275f8bbb52
6496bfb58c25&tpl=/ecfrbrowse/Title45/
45cfr75_main_02.tpl
Reference removed (“reserved”) from
the CFAR website, archived regulations
can be found at:
NIH Grants Policy Statement
(GPS) (Mar 2015):
http://grants.nih.gov/grants/policy/nihgp
s/index.htm
http://www.gpo.gov/fdsys/browse/collectionCfr
.action?collectionCode=CFR&searchPath=Title+4
5&oldPath=&isCollapsed=true&selectedYearFro
m=2013&ycord=1332
Grants Policy Statement (GPS) (Oct
2013):
http://grants.nih.gov/grants/policy/policy.htm#
gps
Grant General Conditions (GC-1) (Dec
2014):
http://www.nsf.gov/pubs/policydocs/gc1/dec1
4.pdf
NSF
Proposal and Award Policy and
Procedures Guide (PAPPG) (Dec 2014):
Grant Proposal Guide (Part I) http://www.nsf.gov/publications/pub_summ.js
p?ods_key=gpg
Award Administration Guide (Part II) –
http://www.nsf.gov/pubs/policydocs/pappguid
e/nsf15001/aag_index.jsp?org=NSF
Research Terms & Conditions or
Grant General Conditions dated
prior to Dec 2014
Status or Other Information on Application of the
Uniform Guidance
Grants Policy Statement (GPS) dated 3/31/2015 is
“applicable to all grants issued after 12/31/2014 and all
awards that received supplemental funding on or after
12/26/2014.” The GPS also supersedes the Interim Grant
General Conditions dated Dec 2014.
Significant Changes to the NIH GPS March 2015:
http://grants.nih.gov/grants/policy/nihgps/Significant_Changes_NI
HGPS.pdf
Individual awards/modifications have referenced
regulations that may or may not be in sync with NIH’s
overall guidance. Each award/modification document
should be reviewed individually to determine the
applicable regulations.
Update of GC-1 contingent on update of
Research Terms and Conditions (working
group formed, no expected to be final
until later this year)
NSF listing of changes with the UG:
http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/sigchanges.js
p
NSF is issuing modifications to subject the entire award to
the GC-1 dated December 2014. Once this modification has
been received then the entire award is subject to the
Uniform Guidance.
Agency
DHHS
ONR
DOEn
Uniform Guidance Reference (2
CFR 200)
A-21/A-110 Circular Reference (all
dated prior to 12/26/2014)
Status or Other Information on Application of the
Uniform Guidance
45 CFR Part 75 –to be
determined
HHS Grants Policy Statement (1 Jan
2007)
None
32 CFR Part 32
Standard Terms/Conditions for
Research Grants (Agency Specific)
either Dec 2014 or Feb 2015
Standard Terms & Conditions for
Research Grants June 2011
ONR is handling each modification
differently, review Award for regulation
application
10 CFR Part 605
Standard Terms & Conditions for
Research Grants:
Awards and modifications may refer to or have attached
“Special Terms and Conditions” which cite 10 CFR 605
Department of Energy Special
Research Terms & Conditions
(RTC) dated March 4 2015
http://science.energy.gov/grants/policy-andguidance/
2 CFR 1800
14 CFR 1260
NASA is applying the Uniform Guidance to all new
awards and to the old funding and supplements on
amended awards.
TBD
FAR 52-216.7
FAR 52.216-7 (Alternate II) refers to FAR 31.3 for the Cost
Principles, which still refers to A-21. FAR not yet updated to
refer to the Uniform Guidance
NASA
DARPA*
*Most DARPA awards are Contracts (rather than Grants) which are subject to the Federal Acquisition Regulations (FAR) rather than the CFR.
The FAR references the Cost Principles but to date, still references the A-21 Circular rather than the UG. As such, Contracts are still subject to
the A-21 Circular, rather than the UG, until the FAR references the UG.
CDC
45 CFR Part 75
45 CFR Part 74
CDC has been handling each modification differently,
review Award for regulation application
Agency
Uniform Guidance Reference (2
CFR 200)
45 CFR Part 75
AHRQ
DTRA
Treasury
Interior
A-21/A-110 Circular Reference (all
dated prior to 12/26/2014)
45 CFR Part 74
Status or Other Information on Application of the
Uniform Guidance
Section III of the modifications may refer to 45 CFR Part 74
under Section IV Special Terms & conditions may have
something like “….. the reference to 45 CFR Part 74 or 45
CFR Part 92 in Section III of this NOA is incorrect and is
scheduled to be updated in future NOAs. The correct
citation is 45 CFR Part 75.” This means the entire award is
subject to the Uniform Guidance.
DTRA General Terms & Conditions for Terms & Conditions dated prior to
New awards subject to the UG; awards with supplements
Grant Awards dated 2/9/2015
12/26/2014
still subject to A-21/A-110
Awards refer to the “LITC Grant Application Package and Guidelines.” This document is updated annually so refer to the version applicable as of
the start of the funding period. The 2016 version states “Grant award administrative requirements are set forth in the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR Part 200” which is the Uniform Guidance.
2 CFR Part 1402
43 CFR Part 12 (Reserved, see NIH
Award may refer to 2 CFR 200, 2 CFR Part 1402 AND 43 CFR
above for link to archived CFRs)
Part 12; if new award the UG applies, if supplement then
only supplemental funds are subject to the UG.