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OMB circular A-133:
Uniform Guidance (2 CFR 200):
AAU, COGR and APLU recommend that OMB raise the micropurchase threshold from $3,000 to $10,000 to reflect current practices. As data supports a higher threshold, OMB should consider future adjustments. The UG has introduced a category known as “Micro-Purchases,” defined as purchase transactions up to $3,000, below which there is no requirement to document competition. This was not included in the proposed guidance so ...more »
AAU, COGR and APLU recommend that OMB strongly encourage Federal agencies to issue collaborative/linked awards as an alternative to subawards. Separately submitted collaborative proposals allow two or more PIs/institutions to manage separate awards for a single, unified project.
AAU, COGR and APLU recommend that OMB clarify that where a subrecipient has a current Single Audit report, prime recipients can rely on the subrecipient’s auditors and cognizant agency oversight for routine audit follow-up and management decisions. Science is engendering an increased number of collaborative projects, resulting in significant growth in the number of subawards issued and received by institutions of higher ...more »
AAU, COGR, and APLU recommend that OMB and federal research funding agencies and/or cognizant agencies work with the research community to explore the optional use of alternatives to measures of time as a means of assessing proper use of federal funds (e.g., information provided in progress reports and publications as an alternative to documenting personnel charges) as well as means of reducing reporting requirements. ...more »
AAU, COGR and APLU recommend that OMB clarify the conflict of interest regulations in section 200.112 of the Uniform Guidance. OMB should make a technical correction to the UG, removing “selection of a subrecipient” to clarify that the intent of the regulations is to address conflicts that might arise around how a non-Federal entity expends funds under a Federal award and not to individual financial interests and work ...more »
AAU, COGR and APLU recommend that OMB clarify in regulation that personal activity reports are not required under the Uniform Guidance (UG); that awardees do not have to certify payroll expenses; and that cognizant agency approval is not needed to implement alternatives to effort reporting that meet the UG standards of documentation. The Uniform Guidance provides institutions with increased flexibility to document ...more »
AAU, COGR and APLU recommend that agencies eliminate quarterly financial reports once they have transitioned to subaccounts. Institutions draw down cash by award accounts on a regular basis, typically monthly. This provides agencies with up-to-date financial information and renders additional financial reports unnecessary. Agencies should also consider whether there is a need for annual and final financial reports and ...more »
AAU, COGR and APLU recommend a common federal portal for grants submission, invoicing/cash draw downs, and final reporting (e.g., progress, financial, equipment) with a single set of rules, forms and due dates (potentially using NSF policy and guidelines as a model). A common portal would significantly ease reporting burden. - Consolidate federal proposal and award management systems, including payment systems, optimally ...more »
If a centralized reporting database could be developed that all federal agencies, grantees, subrecipients, etc. would be required to use for reporting, and it would prepopulate many of the fields once the entity enters their FAIN, this would ease a lot of the reporting burden.
However, first, the FAIN would have to start being included in grant agreements so entities have that piece of information to enter.
I am surprised more people haven't been commenting or making suggestions. Do you think it might be due to the fact that most of us are so busy with our jobs, lacking funds, burnt out and trying to pick up pieces of pie because we are spending our own time working and ignoring everything else? Our jobs have become so complicated with reporting and regulations that we don't have time to take care of the people and partners ...more »
Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
There needs to be alignment of Federal Spending elements and the elements in the CDERL and elements like entity classification
Comment from June 10 Data Act Summit breakout session on Recipient Reporting:
I’m interested in Entity Classifications- better classifications, better utilization of existing classifications. I want to, for example, be able to look in USASpending.gov and analyze the dollars going to non-profits.