The Federal Government's Office of Management and Budget (OMB) publishes guidance on the administrative requirements, cost principles, and audit requirement for grants and cooperative agreements.
Effective December 26, 2014, this guidance has changed. Commonly referred to as "Uniform Guidance" or "2 CFR 200", this guidance is replacing federal guidance in OMB Circulars A-21, A-110, and A-133.
Specifically, the Administrative Requirements and Cost Principles detailed within the Uniform Guidance will apply to new and incrementally funded awards effective December 26, 2014. The Audit Requirements detailed apply to audits of fiscal years beginning on or after December 26, 2014, that is July 1, 2015 – June 30, 2016 for the University. Please reference your award document for the guidance applicable to your award.
2 CFR 200: OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
Please note: The University has delayed the implementation of the Uniform Guidance Procurement Standards until July 1, 2016 as provided by the waiver of the procurement rules stated in COFAR FAQ, Section 110-6, released November 26, 2014. In the interim, the OMB Circulars will apply to grants and cooperative agreements.
The Federal Office of Management and Budget (OMB) publishes a number of circulars related to federal sponsored funding.
Circular A-110 outlines uniform administrative requirements for grants and cooperative agreements (not contracts). Each Federal Agency must formally issue its implementation of A-110 (see Agency Implementation).
Circular A-21 establishes cost principles applicable to grants, contracts, and other agreements with educational institutions.
Circular A-133 establishes audit requirements for institutions of higher education and other nonprofits.
Published by the Office of the Federal Register, National Archives and Records Administration (NARA), the Federal Register is the official daily publication for rules, proposed rules, and notices of Federal agencies and organizations, as well as executive orders and other presidential documents.
For Federal Regulations regarding Conflicts of Interest, visit the COI Federal Regulations page.
The FAR was established to codify uniform policies for acquisition of supplies and services by executive agencies. The FARs govern federal contracts just as 2 CFR 200 governs federal grants and cooperative agreements.
For those awards issued prior to 12/26/14, which incorporated the Research Terms and Conditions and which have not been updated through an agency modification to include the Uniform Guidance (2 CFR 200), the applicable terms and conditions may be found on the NSF website.
It is anticipated that a revised set of agency-specific Research Terms and Conditions issued through the Federal Demonstration Partnership will be issued this year. Updates will be posted to this website.
Freedom of Information Act (FOIA) Exemptions
Federal agencies occasionally receive requests for information about university investigators’ proposals or projects. These agencies then contact investigators to inform them that they will provide information about their proposals or projects to an interested party.
Investigators who receive such correspondence should know that under the federal Freedom of Information Act (FOIA), they are not required to disclose all information requested. Under FOIA, there are nine categories of records exempt from mandatory disclosure. Investigators may request that records or portions of records that fall within one or more of these exemptions be withheld. These requests must be made in writing to the originating agency within the timeframe specified by the agency or else all materials will be disclosed. Investigators or Administrators receiving a FOIA request should forward it to the Associate Director for Grants & Contracts in University Research Administration or their URA Manager for immediate attention and assistance.
The nine exemptions to FOIA are listed below. If you would like more information about FOIA and these nine exemptions, contact University Research Administration. – September 1992
Exemptions to FOIA
- Records which are authorized by executive order to be kept secret in the interest of national defense or foreign policy and are so classified pursuant to such executive order.
- Records related solely to the internal personnel rules and practices of an agency.
- Records which are specifically exempted from disclosure by other federal statutes.
- Privileged or confidential trade secrets or commercial or financial information.
- Interagency or intra-agency memoranda or letters which would not be available by law to a party other than an agency in litigation with an agency.
- Personnel and medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal privacy.
- Investigatory records compiled for law enforcement purposes.
- Records related to reports prepared by or for the use of an agency responsible for the regulation or supervision of financial institutions.
- Geological and geographical information (including maps) concerning wells.