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Requirements for federal awards
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.
Navigating the Uniform Guidance
IU’s research administration staff take the lead in ensuring IU’s adherence to Uniform Guidance. For ease of navigation, the Uniform Guidance is broken down into its following subparts:
- Subpart A (200.0 - 200.99) — Acronyms and Definitions
- Subpart B (200.100 - 200.113) — General Provisions
- Subpart C (200.200 - 200.211) — Pre Award Requirements
- Subpart D (200.300 - 200.345) — Post Award Requirements
- Subpart E (200.400 - 200.475) — Cost Principles
- Subpart F (200.500 - 200.521) — Audit Requirements
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
RTC agency implementation statements
Federal agencies working to implement the RTC have published schedules (Research Terms and Conditions Agency Implementation Statements) that are updated periodically.
Appendix A Prior Approval Matrix is an easy-to-view comprehensive guide to agency implementation of the prior approval requirements for Uniform Guidance.
Uniform Guidance details its applicability to different types of award types (e.g. grants, cooperative agreements, contracts).
- Requirements for pass-through entities
- Subawards are to include F&A costs at a subrecipient’s federally negotiated rate if the subrecipient has a negotiated rate established. Otherwise a de minimis rate of 10% of modified total direct costs is to be used unless an alternate rate is specified in the funding agency guidelines or funding opportunity announcement.
Indiana University implementation
Your federal, or federal pass-through, award will include a reference to Uniform Guidance, Research Terms and Conditions, and Agency Specific terms (if applicable). Questions should be directed to the Office of Research Administration (ORA).
Indiana University policies related to Uniform Guidance
- SPA-11-020 Administrative and Clerical Salaries on Federal Sponsored Awards
- SPA-11-021 Computing Devices on Federal Sponsored Awards
- SPA-11-022 Publication Costs on Federal Sponsored Awards
- SPA-11-019 Subrecipient Monitoring on Federal Sponsored Awards
- SPA-11-023 Visa Charges on Federal Sponsored Awards
Subrecipient post-award monitoring guidelines
Indiana University’s adoption of the procurement standards is explained on IU’s Office of Procurement Services or Purchasing website.