Some Answers Still Confusing in Second FAQ from OMB, COFAR

September 5, 2014 | By Jerry Ashworth | Post a Comment

1238327_questionsWhat is it with the Office of Management and Budget and holidays? After issuing the uniform grant guidance last year on the day after Christmas (and setting an implementation date for Dec. 26 of this year), OMB and the Council on Financial Assistance Reform recently released its second set of Frequently Asked Questions — on the Friday afternoon before Labor Day! Perhaps they wanted to give the grants community something to read while folks were taking their last summer beach vacation.

Regardless, the 30-page FAQ, which includes in full the questions and answers from the first FAQ document that OMB and COFAR released in February, attempts to answer many questions they received from stakeholders over the past year. While some answers are pretty solid “yes or no” answers, others are vague and, as we’ve seen in reporting on the document, are still unclear.

For example, one question asked whether the 10 percent de minimis rate in §200.414 for new organizations that have never negotiated an indirect cost rate was available to governmental organizations or tribal governmental entities. In its answer, OMB and COFAR responded that yes, the de minimis rate was available as long as they meet the requirements specified in §200.414(f). Okay, I got that one.

However, answers to other questions weren’t as clear cut. Consider the following question related to prior approval in §200.413: “I have a federal award that qualifies as a major project or activity, and I’m directly charging administrative costs to it. When I receive incremental funding on my project next spring, I understand I am going to now need prior written approval from the federal awarding agency to continue charging those costs to the new incremental funds. If I list my intention to continue charging those costs in my next continuation progress report and the federal awarding agency issues my award without making any mention of my request, does that count as prior written approval?”

Instead of a yes or no, OMB and COFAR responded, “It depends. Nonfederal entities should refer to the terms and conditions of their federal award or address their questions to the federal awarding agency awarding official (or pass-through entity if appropriate) to clarify when pre-approval has been granted.” So, it appears this is a site-specific question.

And then there were some answers that we thought needed more clarification. For example, one question asked when nonfederal entities may begin to submit proposals for indirect cost rates based on the uniform guidance? The answer, “Nonfederal entities may begin to submit actual cost proposals based on the uniform guidance when they are due for fiscal years that begin on or after Dec. 26, 2014. For example, if a nonfederal entity is required to submit a rate proposal based on FY 2014 actual costs to set rates for FY 2016, the rate proposal can be developed using the provisions in the uniform guidance.” We were a bit confused by the wording used in this answer and felt more explanation on who’s fiscal year was needed here.

I would advise all grant stakeholders to take a look at this FAQ. It may address some questions you may have had with the guidance. It is essential that everyone be fully aware of the changes coming from the uniform guidance as the implementation date continues to move closer and closer.

Are there any unanswered questions that you have about the uniform guidance? Let us know and we’ll try to get an answer for you.



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