The Office of Management and Budget (OMB) issues guidance regarding government-wide policies for the award and administration of Federal financial assistance, often referred to as the Uniform Guidance. The most recent revision to Uniform Guidance (2 CFR 200) is effective October 1, 2024.
Federal sponsors of research have begun to announce their implementation plans related to the October 1 Uniform Guidance revisions (see agency implementation links below). We also outline guidance specifically related to University of Iowa applications for sponsored research below.
University of Iowa specific budget guidance
Equipment capitalization and MTDC base (F&A recovery) on subawards (2 CFR 200.1)
While the Uniform Guidance revisions allow the capitalized equipment threshold to increase to $10,000, and authorizes a Modified Total Direct Cost (MTDC) base increase for subawards to $50,000, neither of these increases will be effective immediately for the University of Iowa.
The UI’s current equipment definition and MTDC base with recovery of F&A on the first $25,000 of subawards remain in effect. The equipment definition and MTDC base are both specified in the University’s federally negotiated F&A rate agreement. Therefore, the following policies remain in effect for the UI for the duration of our current F&A rate agreement through 6/30/2026 or until amended:
- The UI capitalized equipment cost remains at $5,000 or more per-unit.
- The UI will recover F&A on the first $25,000 of subawards.
Subrecipient de minimis F&A rate (2 CFR 200.414)
- The de minimis F&A rate for subrecipients that do not have a federally negotiated F&A rate will increase from 10% to 15%. The change will not be effective retroactively. Subawards issued with the current 10% de minimis rate will remain at that rate. Sponsor specific limits on F&A, such as the NIH 8% F&A limit for foreign subrecipients, will remain in effect.
The UI will not negotiate F&A rates with subrecipients. If a subrecipient does not have a current federally negotiated F&A rate agreement, the de minimis rate will apply (see https://dsp.research.uiowa.edu/subawards-university-iowa).
Fixed amount subawards (2 CFR 200.333)
- The Uniform Guidance increases from $250,000 to $500,000 the amount of fixed amount subawards a recipient may provide with prior written approval from the federal agency.
The UI’s default approach remains to issue cost-reimbursement, rather than fixed amount subawards. Fixed amount subawards are used only in special circumstances and require additional monitoring. Please contact DSP prior to including a fixed amount subaward in an application.
Participant and Participant Support Costs (2 CFR 200.456)
OMB added a definition of participant and further defined participant support costs in the 2024 revisions. They clarified who is considered a participant, what participant support costs are and advised these changes must be documented in the recipient's or subrecipient's written policies and procedures and treated consistently across all Federal awards.
Participant generally means an individual participating in or attending program activities under a Federal award, such as trainings or conferences, but who is not responsible for implementation of the Federal award. Individuals committing effort to the development or delivery of program activities under a Federal award (such as consultants, project personnel, or staff members for a recipient or subrecipient) are not participants. Examples of participants may include community members participating in a community outreach program, members of the public whose perspectives or input are sought as part of a program, students, or conference attendees.
Participant support costs means direct costs that support participants (see definition for Participant in § 200.1) and their involvement in a Federal award, such as stipends, subsistence allowances, travel allowances, registration fees, temporary dependent care, and per diem paid directly to or on behalf of participants.
Note: The University of Iowa’s Travel Policy does not allow for temporary dependent care related to travel. Based on UI’s policy costs related to temporary dependent care are not allowable costs on sponsored projects.
Additional Uniform Guidance revisions will be covered during the September 23, 2024, webinar for campus. Watch for additional RAD notices with more information.
Agency Implementations of the Uniform Guidance, effective Oct. 1, 2024
Federal-Wide Research Terms & Conditions (RTC)
The Federal-Wide RTC will no longer be referenced in awards made on or after Oct. 1, 2024. The RTC web page (https://www.nsf.gov/awards/managing/rtc.jsp) will remain available for prior awards made subject to the RTCs. This web page includes links to the RTC Prior Approval Matrix, Subaward Requirements, and National Policy Requirements.
Instead, individual federal agencies will implement and post their own adopted versions of Terms and Conditions, Prior Approval Matrices, and other requirements. Stay tuned for updates and links that are shared by the agencies.
National Science Foundation (NSF)
NSF has revised the Grant General Conditions (GC-1), effective Oct. 1, 2024, including the Summary of Changes: https://www.nsf.gov/awards/managing/general_conditions.jsp?org=NSF
NSF implements 2 CFR in two ways: 1) through the NSF Proposal & Award Policies & Procedures Guide (PAPPG) and 2) the Award Terms and Conditions.
*In the case of inconsistency between the PAPPG and 2 CFR 200, the coverage specified in 2 CFR 200 applies. There will be a new statement to this effect on the NSF program pages and on the PAPPG.
National Institutes of Health (NIH)
NIH will implement the 2 CFR 200 provisions effective October 1, 2024, for competing and non-competing awards. Stay tuned for an NIH Guide notice regarding the changes.
National Aeronautics and Space Administration (NASA)
NASA Grants Policy and Compliance has published Grant Notice 24-01 informing NASA grant and cooperative agreement recipients and applicants about upcoming changes to NASA’s grant policies being released on October 1, 2024, which implement revisions to 2 CFR and National Security Presidential Memorandum-33.
The Grant Notice, published on the Grants Policy and Compliance website, outlines what proposers and grant recipients can expect in the coming weeks, as NASA prepares to release updated grant guidance in the NASA Grant and Cooperative Agreement Manual.
Environmental Protection Agency (EPA)
EPA is hosting a series of webinars to review 2 CFR Part 200 updates. The first webinar is scheduled for October 9, 2024 and information on the subsequent webinars is forthcoming. Register at https://forms.office.com/Pages/ResponsePage.aspx?id=uuQPpMer_kiHkrQ4iZNkAHEr6KgFYkhHnCdSKDAPrbFUNjcyS0dNOFpUMUVZNkxXMzVZTkI1TDE3WC4u.
Additional Information
DSP and GAO will share additional agency updates as we become aware of the changes. DSP and GAO will also host a webinar for campus Tuesday, September 24 at 1:30 p.m. to highlight Uniform Guidance updates and answer questions. We will share the webinar link in a subsequent RAD notice. The webinar will be recorded and posted to DSP’s HawkID password protected site for UI users.
If you have any questions, please do not hesitate to contact DSP, 319-335-2123, or era@uiowa.edu
