Uniform Guidance

The U.S. government requires recipients of federal grants, such as Indiana University, to adhere to specific terms and conditions. The overarching requirement IU must follow is the Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Part 200, referred to as Uniform Guidance.

Uniform Guidance is a government-wide framework for grants management and provides an authoritative set of rules and requirements for federal awards. It is the foundation on which federal agencies develop their policies for grants and cooperative agreements.

Each of the federal agencies is responsible for incorporating Uniform Guidance into their grant terms and conditions. Many of the agencies have partnered with the Federal Demonstration Partnership (FDP) to develop standard Research Terms and Conditions (RTC), which simplify implementation of the Uniform Guidance for research and research-related awards made by these agencies:

• DHS U.S. Department of Homeland Security
• DOC U.S. Department of Commerce
• DOE U.S. Department of Energy
• DOT/FAA U.S. Department of Transportation/Federal Aviation Administration
• EPA U.S. Environmental Protection Agency
• NASA National Aeronautics and Space Administration
• NIH National Institutes of Health
• NSF National Science Foundation
• USDA/NIFA U.S. Department of Agriculture/National Institute of Food and Agriculture

Revisions to Uniform Guidance

On April 22, 2024, OMB issued major revisions to the Uniform Guidance, effective for awards issued on or after October 1, 2024. Awards issued prior to October 1, 2024, are subject to the previous revision of the Uniform Guidance. The applicable terms and conditions section of an award should specify which version of the Uniform Guidance governs the funding period.

Approval matrix

Appendix A: Prior Approval Matrix serves as a user-friendly, comprehensive reference outlining how various federal agencies implement the prior approval requirements under the Uniform Guidance. Please note: the matrix has not yet been updated to reflect the revised Uniform Guidance applicable to awards issued on or after October 1, 2024.

Award types

Uniform Guidance details its applicability to different types of award types (e.g. grants, cooperative agreements, contracts).

Subaward requirements

• Requirements for pass-through entities
• Subawards must include F&A costs at the subrecipient’s federally negotiated rate, if one has been established. If the subrecipient does not have a negotiated rate, a de minimis rate is to be used—15% of modified total direct costs (MTDC) for proposals submitted on or after October 1, 2024, and for awards issued or modified on or after that date—unless an alternate rate is specified in the funding agency guidelines or funding opportunity announcement. Subawards using the de minimis rate on awards that have not been issued or modified after October 1, 2024, will continue to apply the previous 10% rate.