What’s in it for Researchers? Proposed Changes in Federal Research Guidance (A-81)

Preliminary! Still sleuthing! What’s in it for Researchers? Proposed Changes in Federal Research Guidance (A-81) Pamela A. Webb Associate Vice President for Research pwebb@umn.edu

Comments Due by 11:00 p.m. on June 2, 2013 Submit comments to: "regulations.gov" under Docket Number OMB-2013-0001

Purpose of Change • Combine 8 circulars into a single consolidated set of federal guidance • A-21, A-110 and A-133 superseded • Respond to input received for regulatory improvements submitted last year • Improve efficiency & transparency • Reduce fraud, waste and abuse • Achieve best program outcomes while ensuring financial integrity

Component Parts 241 pages! • Subchapter A – General Provisions • Subchapter B – Pre-award Requirements • Subchapter C – Federal Award Notice • Subchapter D – Inclusion of Terms and Conditions in Federal Award Notice • Subchapter E – Post Federal Award Requirements • Subchapter F – Cost Principles • Subchapter G – Audit Requirements • Subchapter H - Appendices A-110 A-110 A-21 A-133

What changes might researchers care about?

Funding Opportunity Announcements Generally Positive • Must be available and open for submission for at least 30 days • Unless a different period is required by statute or exigent circumstances as dictated by the agency head • Requires a standard format

Award Notices Positive • Create a unique, government-wide identifier number for each award • Terms and conditions are spelled out

Cost-Sharing Positive • Voluntary Committed Cost-Sharing is not expected and is not to be used as a factor in the review of applications.

Role of Students Negative • Eliminates language recognizing the dual role of students (research and training is inextricably linked) • Will ask for this desirable language to be restored.

F&A Rates Impact Uncertain • Deviations from federally negotiated rates only allowed when • Exceptions are provided in statute or regulation • Agency Head has approved a deviation • OMB is notified

Progress/Financial Reporting Negative • New requirement to relate financial data to performance accomplishments whenever practicable (including unit cost data) • Agencies should provide clear performance goals, indicators, and milestones expected • May lead to new reporting burdens and financial accountability measures

Admin and Clerical Costs Mixed • Salaries of admin and clerical staff allowable as a direct charge when: • individuals involved can be specifically identified with the project or activity; • are integral to the project • such costs are explicitly included in the budget; • the costs are not also covered in indirect costs

Project Management Costs Positive • Charges to federal awards may include ... developing and maintaining protocols (humans, animals, etc.), managing substances/chemicals, managing and securing project-specific data ..

Mixed Salary/Effort Reporting • Effort Reporting – Elimination of examples of acceptable systems allows room for other models as does possibility that reports can be integrated with a payroll system; allows “responsible person” to certify;

Mixed Salary/Effort Reporting • Requires consistent definition of a full-time workload in order to qualify for extra service pay • Must apply to all employees in a given class (not just federally-funded employees.) • Supplementation amount is commensurate with the base pay rate and amount of additional work performed • Inserts new obligation to review budget estimate quarterly

Dependent Care during Travel • Dependent care costs that are the direct results of the individual’s travel requirement for the federal award and are only temporary during the travel period are allowable. • If used, must be available regardless of fund source

Computing Devices <$5K Positive • Allowable as supplies cost for devices that are essential and allocable, but not solely dedicated to the performance of the Federal award

Subrecipients Mixed • Explicit obligation of the prime to honor subrecipient’s federally negotiated F&A rate • Subrecipients without negotiated rate can have an automatic 10% F&A rate • Federal agency can impose their own documentation requirements on grantees to verify how they determined that a transaction is a subaward v. vendor • Audit threshold raised to $750K (from $500K) • More prescriptive requirements on subrecipient monitoring • Primes may be able to use federal audit management decisions

Forthcoming Dates • APRIL 19th • COGR expected to release preliminary draft comments • University offices asked to provide comments to Pamela for use in preparing University draft • ~MAY 13th - • University draft available

What’s in it for Researchers? Proposed Changes in Federal Research Guidance (A-81)