Sneak Preview: COFAR Updates FAQ on Uniform Grant Guidance

October 15, 2015 | By Jerry Ashworth | Post a Comment

xgran_bookshot(The following was excerpted from a recent article in the Federal Grants Management Handbook.) The Council on Financial Assistance Reform (COFAR) recently updated its Frequently Asked Questions (FAQ) document addressing provisions within the Office of Management and Budget’s (OMB’s) uniform grant guidance. The document, now in its third version, contains 23 new questions and answers, along with the remainder of the questions and answers contained in the second version released in November 2014. COFAR also revised the answers for three questions included in the November 2014 version in light of subsequent technical amendments to the uniform guidance.

COFAR, an interagency group of executive branch officials charged with providing recommendations to OMB on policies for grants and cooperative agreements, issued the 38-page FAQ to provide additional context and background on the guidance to help stakeholders understand policy changes. If there is any discrepancy between the FAQ and the uniform guidance, the guidance has final authority. Additionally, other questions related to a particular program should be addressed to the federal awarding agency or pass-through entity in the case of a subrecipient.

The document now contains about 115 questions and answers. Many of the new questions focus on indirect cost rate issues, including the new de minimis rate (§200.414). One new question focused on an organization that previously had a negotiated indirect cost rate, but all its federal awards had since expired, along with its negotiated indirect cost rate. Now that it has received a new federal award, is the organization eligible for the 10 percent de minimis rate? COFAR responded that “organizations that experience a break in federal relationship” are not eligible to receive the 10 percent de minimis rate when receiving a new award, adding that the rate is specifically limited to a nonfederal entity that has never received a negotiated indirect cost rate (§200.414(f)). COFAR noted that “it is expected that organizations that have experience developing and negotiating rates have adequate resources to develop a new indirect rate.”

In a related question, an organization asked whether the de minimis rate it received at the beginning of an award would be applicable throughout the period of performance of the award. COFAR answered that the de minimis rate may or may not be applicable during the entire period of performance of an award. It noted that a nonfederal entity may use the 10 percent rate indefinitely until it elects to negotiate an indirect cost rate, which it may apply to do at any time. Indirect cost rates are generally negotiated based on a nonfederal entity’s fiscal year, not the period of performance of an award, COFAR added.

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site).

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