Open Issues - Find out the latest information available

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What is the Uniform Guidance?

Important Changes in the UG

Agency Implementation

Open Issues

The following is a list of open issues - regulations in the guidance that are being questioned by COGR or are otherwise not yet resolved.

Research Terms and Conditions (RTC) expire on 12/26/2014. FDP is working with federal officials to secure new or existing RTC terms. The organization prepared a white paper on Standard Terms and Conditions for the April 14, 2014 joint FDP/COGR/Federal Partners Meeting. (Page 8 of the White Papers). 

General Procurement Standards (200.318-320).  UG standards represent a potential administrative burden for IHE’s (Institutions of Higher Education). (See the changes related to procurement.) COGR submitted a request to OMB to review the Procurement and Terminal Leave issues (Read the letter dated 6/17/2014.) The Federal Demonstration Partnership collected survey data which was provided to OMB to show the impact of the UG Standards. (Read the minutes from the January 2015 meeting.) The University of Maryland College Park will continue to follow the procurement requirement of OMB Circular A-110 and will utilize the grace period allowed in the Uniform Guidance and as extended by the Office of Management and Budget technical corrections. For more information on UMCP’s procurement policies, go to http://www.purchase.umd.edu

Most Recent COGR Requests for Clarification: Listed here are three recent letters that COGR has sent to the COFAR applicable to the OMB Uniform Guidance: 1) September 26, 2014 - request to clarify the definition of MTDC and use of the term "subcontract" - click here for the letter; 2) October 9, 2014 - request to incorporate technical corrections into the final version of the Uniform Guidance - click here for the letter; and 3) October 10, 2014 - request to change the trigger for DS-2 submission from $50 million of federal awards to $50 million of CAS-covered contracts - click here for the letter.

Questions?

Contact your ORA contract administrator for technical questions or SPAC for financial matters.

 

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