Codify the FAQs in the New 2 CFR 200
Codify the Frequently Asked Questions (FAQs) to eliminate potential interpretation differences of future auditors and inspectors general between Uniform Guidance and FAQs.
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Grantees
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Grants practices and processes
Key Participants: grantees, cooperative agreement holders, subgrantees
- Question: If you could change one thing that would ease your reporting burden associated with your grants or subgrants, what would it be (e.g., time, cost, resource burden)?
- Question: If you have reporting requirements to the Federal government, how are those met? (feel free to be specific about what is reported to whom and through what mechanism)
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities/functions would you include?
OMB circular A-133:
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditee?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditor?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting to the Federal Audit Clearinghouse?
Uniform Guidance (2 CFR 200):
- Question: Are there requirements in the new 2 CFR 200 that need additional clarification for improved implementation with reduced administrative burden ?
- Question: What are the perceived burdens associated with the new standards such as the documentation of salaries & wages and time & effort (2 CFR 200.430), subrecipient monitoring (2 CFR 200.331), procurement standards (2 CFR 200.317- 2 CFR 200.324)?
- Question: How can the administrative burden associated with standards compliance be lowered?
More guidance in FAC on Subrecipient Monitoring
Princeton University suggests that the Federal Audit Clearinghouse (FAC) should provide more guidance (e.g. definitions, acronyms) on how to access and leverage annual reports to monitor subrecipients per Uniform Guidance requirements in order to reduce the burden. Assistance in navigating through the forms similar to guidance provided to comply with the Federal Funding Accountability and Transparency Act (FFATA) would ...more »
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Raise the Questioned Cost Threshold Above $25,000
The OMB Compliance Supplement for the Single Audit increased the threshold for known or likely questioned costs from $10,000 to $25,000. Princeton University suggests that consideration should be given for a threshold higher than $25,000, particularly when extrapolation could occur throughout the rest of the organization. An alternative solution would be to make the threshold related to a percentage of expenditures ...more »
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Remove Administrative Components from Progress Reporting
The RPPR continues to evolve into more financial and administrative reporting than it has to do with scientific/technical progress ever since you eliminated annual FFR's for SNAP grants. Institutions are getting hammered on follow-up questioning from Grants Mgmt Specialists regarding unobligated balances, effort reported on the participants tab, other support, use of IDP's and MyNCBI noncompliant pubs. Many followup ...more »
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Eliminate Subcontracting from Prime Awardees
Grant Proposals indicate all institutions involved and require separate budget submissions. Not only is it a waste of taxpayer $ to pay institutions F&A on the first 25K of each sub, but it is so inefficient to dole out the $ to us to turn around and pay out the subs when you can utilize a LOC payment system. Then you impose subrecipient monitoring on us and everybody has to document everyone else's audit report/FCOI ...more »
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Moderate the Audit Climate
Research administrators work in a world of constant and continuous audits by various Federal OIGs. These are in addition to the ongoing annual "A-133" audits designed to attest to our having systems and procedures in place to provide proper stewardship over Federal funds under our purview. The OIG audits have been extremely aggressive and are characterized by initial allegations of wrongdoing, high cost disallowances, ...more »
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Make Conflict of Interest policies consistent across agencies
Since the publication of the Uniform Guidance UG), institutions have seen various Conflict of Interest (COI) terms and conditions embedded within broad agency announcements and proposal solicitations, despite the lack of formal agency-wide policies or guidelines in most cases. The specific requirements for what financial interests and relationships need to be disclosed, the nature and timing of reviews, and even definitions ...more »
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Establish consistent requirements for disclosure of FCOI
Since the implementation of the PHS requirements for disclosure of potential financial conflicts of interest for all key personnel at the time of proposal, this has been one of the most burdensome requirements for Faculty and staff at the University of Chicago. Last year alone we were required to obtain over 5,000 disclosures of financial interests before PHS proposals could be submitted, while only 115 of those disclosures ...more »
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Volunteer timesheets
Allow for easier way to obtain and record RSVP volunteer timesheets. Currently the signature piece is unclear. As long as the supervisor at the site signs off that should be more than enough.
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Frequency of reports
There is much redundancy in the current reporting. Suggest the following: 1) one annual Progress Report 2) Performance Measure surveys ONLY to be done ONCE in the 3 year grant period 3) when submitting renewal grants if the workplans are not changes have a box to simply check that off. 4) same for budgets 5) Accessability and Site Safety checks only to be done ONCE in the 3 year grant period and reflected in the MOU. ...more »
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Require Agencies to Adopt Common Research Terms and Conditions
AAU, COGR and APLU recommend that OMB require Federal agencies to adopt common research terms and conditions. We believe NSF, NIH, USDA NIFA, NIST, NOAA, DOE, FAA, EPA and NASA are creating common RTCs, but other agencies have opted out. Clear and consistent data definitions are also needed. Not all federal agencies are signing on to federal-wide research terms and conditions for federal awards under the Uniform Guidance ...more »
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Eliminate the DS-2 Requirement for IHEs
AAU, COGR and APLU recommend that OMB eliminate the DS-2 requirement for institutions of higher education. The DS-2 is a document setting forth an institution’s accounting practices with regard to federal funds that requires approval by the institution’s cognizant agency for indirect costs. It is a transposition of accounting policies and practices that are already documented elsewhere, usually on an institution’s website ...more »
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