As most grant professionals whose work is impacted by federal grants during the pre-award or post-award management phases are aware, the Office of Management and Budget’s Uniform Grants Guidance (previously known as the "Omni-Circular" and "Super Circular") has modified specific administrative and cost requirements pertaining to federal grants and contracts.
While a number of articles and blog posts have focused on the crosswalk between the new guidance (prior to December 26, 2014) and the previous guidance,1 and its potential impact on grantees and sub-grantees, there has been minimal information pertaining to best practices and applicability in the real world. Based on my research, this information is still in progress as grantees and sub-grantees begin to implement measures to adhere to the Uniform Guidance. However I have identified some steps that grantees and sub-grantees can do to prepare for the change.
1For those who received awards prior to the December 26, 2014, adoption of the Uniform Guidance, note that you are still held responsible to adhere to the previous OMB circulars. Make sure you check your notice of grant award to confirm.
If you Google “Uniform Guidance," I am certain that you would find thousands of hits pertaining to webinars, meetings, conference sessions and guidance documents offered by training providers, state agencies, and other entities. These trainings vary from providing an overview of the guidance itself to actual feedback on the implications of the circular in a grantee’s work. Some of the comments and feedback includes:
- Adoption of more robust policies and procedures
- Enhanced account management and internal controls to ensure transparency and flow of funding
- Evaluation planning and measurement processes that gather quantitative and qualitative data to support the implementation of grant awards.
- Increased flexibility to administer 10% indirect cost rate for those grantees without an approved indirect cost rate
- Higher threshold for A-133 Single Audit to $750,000 total annual federal grant funds received vs. $500,000 previously
While this training and review process may seem laborious, ultimately it will strengthen your organization’s ability to adapt to the changing federal funding landscape. It seems prudent to take advantage of some of the online webinars hosted by the Council on Financial Assistance Reform, or COFAR, or search for presentations through SlideShare.
Rethink the Way You Do Business
With the increased federal government (now trickling down to state and local agencies) focus on transparency, efficiency, and performance measurement, this has given many pause on how to adapt. Ultimately, with any major change the impacts grant seeking and grants management work, this provides an opportunity for organizations to change the way they do business. Some considerations are noted below:
- Do you have policies and procedures that dictate resource requirements and expectations for addressing various grants lifecycle changes?
- Do you have to develop a revised strategic plan to ensure you are in compliance with the Uniform Guidance?
- Do you have to seek additional resource to manage the grant processes?
- Will you be able to ensure the transparency of your funding for external review?
These considerations pertaining to performance measurement, financial management, and indirect cost rate use will be addressed in subsequent posts. Even though we do not have all the answers, at least we have outlined the questions and potential risks, and can develop solutions from this information.
Free 2 CFR 200 (UGG) Training Videos
- VIDEOS: Uniform Guidance Simplified (Gil Tran, OMB)
- VIDEOS: Uniform Guidance Fundamentals (Victoria Collin, OMB)
- VIDEOS: Question & Answers about Indirect Costs (Panel)
- VIDEOS: Uniform Guidance Indirect Cost Training (Mak Karim, HHS)
- VIDEOS: COFAR Promising Practices (Panel)
See All Posts