OMB Uniform Guidance

Referred to by many names: the Omni Guidance, the Omni Circular and Super Circular, and the Uniform Grant Guidance, -- the new regulations located at 2 CFR 200, seek to consolidate a number of OMB Circulars. Here, we will refer to it as the “OMB Uniform Guidance.”

November 2014 Update

The NSF is the only federal agency to date that has proposed any updates to comply with the Uniform Guidance.  A revised version of the Proposal & Award Policies & Procedures Guide (PAPPG), (NSF 15-1) has been issued. The PAPPG has been revised to implement the Uniform Guidance. The PAPPG is comprised of documents relating to the NSF's proposal and award process and consists of the: 
(a) Grant Proposal Guide (GPG) for guidance on the preparation and submission of proposals to NSF; and
(b) Award & Administration Guide (AAG) to guide, manage, and monitor the award and administration of grants and cooperative agreements made by the Foundation.

 Timeline

April-June 2014 Uniform Task Force Reviews and Discovery
June 26, 2014 Federal Agencies submit proposed implementations
December 26, 2014 Federal implementation goes into effect
July 1, 2015 Beginning of first UNC Charlotte fiscal year under the new guidance

FAQ

Following are some basic Questions and Answers about the OMB Uniform Guidance.

What will happen to A-110, A-21, A-133 and other OMB circulars?

The new OMB Guidance combines and replaces 8 different circulars (including A-110, A-21, and A-133) into one piece of guidance. Much of it is simply consolidated.

How will the Federal agencies implement the OMB Guidance?

Federal agencies have until June 26 to submit any proposed implementations of the new guidance to OMB. OMB then will work with the agencies to see that the agency implementations are acceptable and implemented by the December deadline.

How will we respond?

This will require that ORSO, OPD and GCA update policies and procedures over the coming year. We are forming a Task Force to evaluate the Uniform Guidance further and assess the impact and implications. As we determine a course of action, a schedule will be provided to communicate how processes will change. If any training is needed we will announce that as well.

We will need to make sure there is a solid training plan for ORSO, OPD and GCA and campus research administrators.

Where can I see the full source material?

The new OMB Guidance is located at 2 CFR 200. The regulations are broken into the following subparts.

What does each Subpart cover?
  • Subpart A - Acronyms and Definitions
  • Subpart B - General Provisions
  • Subpart C - Pre Award
  • Subpart D - Post Award
  • Subpart E - Cost Principles
  • Subpart F - Audit Requirements

References and resources to learn more

2 CFR 200 Uniform Guidance (12/24/2013) (as published in the Federal Register on 12/26/2013).

The "Crosswalk" (Cross references previous circulars with new guidance).

Uniform Guiance Training Chart

Uniform Guidance - Chart on issues that impact the management of awards

Uniform Guidance Cost Principles Chart