FEDERAL UNIFORM GUIDANCE- WHAT PI'S NEED TO KNOW

The elements below represent a change from the previous Federal Regulations. Not all changes are noted, only those likely to significantly affect the UTHealth research community. In all cases, “agency” refers to the Federal awarding agency. Awards are subject to the following requirements in the order to be followed:

1. Award-specific requirements as stated in the award document(s)
2. Agency –specific terms & conditions
3. Federal Regulations The Award documents and the Agencies’ policies and procedures need to be reviewed to determine specific regulation applicability and interpretation

The Award documents and the Agencies’ policies and procedures need to be reviewed to determine specific regulation applicability and interpretation.

SIGNIFICANT CHANGES UNDER THE FEDERAL UNIFORM GUIDANCE

Prior Approval	Additional prior written approvals have been added to the regulations including re-budgeting, cost share, and participant support. Some agencies have delegated the prior approval authority for certain actions to the institution. As Agency deviations are currently in flux, review the Award document for specific information and/or contact your PAF Administrator for assistance.
Travel	You must document how each individual’s travel is necessary to the Federal award.
Use of Computers for non-Award Activities	Computing devices under $2,000 are considered supplies, while $2,000 or more are considered general purpose equipment. All computing devices can be directly charged to awards if they are essential and necessary to complete the project work, even if they are not solely dedicated to the project. Devices costing $2,000 or more must be identified in the approved budget or approved in writing by the sponsor.
Administrative & Clerical Staff Costs	Administrative and Clerical salaries may be allowable as direct costs only if specific individuals and their work can be identified as integral (necessary) to perform the proposed scope of work. Examples include organizing a conference, managing travel for a large number of participants, organizing large data sets.
Dependent Care Costs during Conferences	For conference awards, the costs of identifying, but not providing locally available dependent-care resources are allowable.
Relative to Your Research Internal Controls	All organizational levels of the institution (UW) must have robust internal controls documented and followed to ensure compliance with terms, conditions, and regulations of the award.
90-day Close Out	Final progress, financial, and other reports are due no later than 90 calendar days after the end date of the period of performance.
Record Retention	Electronic records are preferred to paper records. Periodic quality control reviews are required.
Participant Costs (Trainees, Students)	Participant support costs are exempt from F&A and require agency approval prior to inclusion in the budget and to re-budget for other purposes.
Publication & Printing Costs	Costs of publication or sharing of research results may be charged to the project, even after the end of the award period, but must be recorded as an expense within 90 days of the end date of the award.
Pre-Award	Costs incurred prior to the effective date of the award must be necessary for efficient and timely performance of the award.
Program Income	For all awards generating revenue (Program Income), this income is to be used for costs in support of the project unless the agency specifies otherwise. Agencies may require accountability for income earned after the award ends.
Sub-Recipient Risk Assessment	Assessment (due diligence) of sub-recipients, as well as the monitoring & management of sub-recipients has been clarified and redefined.
F&A Rates for Sub-Recipients	Sub-recipients are entitled to receive their federally negotiated F&A rate or, if they do not have one, a 10% rate, unless agency restricted.
Short-Term Visa Costs	Short term visa costs are allowable under certain conditions, but long term (immigration) visa costs are unallowable.
Value Added Taxes (VAT)	VAT charged by a foreign government for the purchase of goods or services that is legally required to be paid in the foreign country is allowable.
Exchange Rate Fluctuation	Cost increases for fluctuations in exchange rates are allowable, subject to the availability of funding and prior approval by the agency.