Reporting and DATA Act Open Dialogue Ideas

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 »

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 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 »

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 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 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 »