The Office of Management and Budget (OMB)’s “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” (2 CFR part 200), (you may also hear it referred to as the “Uniform Guidance” or “UG”), published in December 2013, provided a government-wide framework for administrative requirements, cost principles, and audit requirements when using Federal funds awarded to non-Federal entities. These requirements are applied to NIH grants and impact your management of these awards. Once the U.S. Department of Health and Human Services (HHS) developed its regulation (45 CFR Part 75) describing how HHS will implement the Uniform Guidance (as announced in the Federal Register in December 2014) my office began work to develop Interim Grant General Conditions, which we published in February.
The NIH Interim Grant General Conditions apply to all new and supplemental funding provided by Notices of Award issued on or after December 26, 2014. The document updates Notice of Award information to align with the new Federal-wide requirements. Many of these changes were based on policy changes that you, the extramural community, suggested to OMB in their earlier requests for input. Such highlights include:
- Family-friendly policies allowing grantees more flexibility to address temporary dependent-care costs
- Updated rules on charging administrative and clerical costs to grants as direct costs
- Institutions of higher education (IHEs) or nonprofit organizations that have never received a negotiated indirect cost rate may choose to use a de minimis rate of 10% of modified total direct costs (MTDC) which may be used indefinitely
- Clarification on how to treat costs of computing devices that are necessary and support the work of, but are not solely dedicated to, a Federal award
NIH will use these Interim Grant General Conditions until an updated Grants Policy Statement is published which will be after the close of the HHS implementation comment period when final HHS implementation plans are released.
We realize there is a lot of information for our grantee institutions to go through, so we will continue to update our frequently asked questions page on this topic. In addition, my staff will host a webinar to talk you through these changes, so sign up if you are seeking additional information.