On December 26, 2013 the Office of Management and Budget (OMB) released its final rule of “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” This guidance to federal agencies streamlines and supersedes guidance that was previously contained in eight different circulars. For SDSU Research Foundation, this new guidance will supersede OMB Circular A-133 (Audit requirements), 2 CFR Part 215 (formerly OMB Circular A-110 Administrative requirements), and 2CFR Part 220 (formerly OMB Circular A-21 Cost principles).

Federal agencies such as NIH, NSF, and US Department of Education must develop their own agency-specific policies that conform to the Uniform Guidance. Non-federal entities, such as SDSU Research Foundation must examine and revise their internal policies to ensure consistency with the Uniform Guidance and with agency-specific policies. The research foundation established a team that is currently reviewing our internal policies in preparation for the implementation of this new guidance. Research foundation staff are also active members of the CSU Uniform Guidance Implementation team which is reviewing system-wide policies to ensure compliance with the new guidance.

The Uniform Guidance administrative requirements and cost principles will apply to new and incremental funding awarded after December 26, 2014. Existing Federal awards will continue to be governed by the terms and conditions under which they were awarded.

Subpart F, Audit Requirements, will apply to audits of non-Federal entity fiscal years beginning on or after December 26, 2014. This will be Fiscal Year July 1, 2015 to June 30, 2016 for the Research Foundation.

Additional information about the Uniform Guidance is available at the Council on Financial Assistance Reform (COFAR) website. The COFAR website contains background information, FAQs, and links to the Uniform Guidance and supplemental materials. (https://cfo.gov/cofar/)