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Federal Policies

Federal Policies

In 2014, the White House Office of Management and Budget (OMB) overhauled the circulars which had provided guidance to the awarding agencies and recipients of federal funding for many years and created the Uniform Guidance. 
On December 26, 2014, OMB issued the new guidance document, formally titled Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

Federal Agency Policies

Federal awards are subject to the requirements of 2 CFR 200 (Uniform Guidance) or applicable FAR clauses. The UG and FAR provide the overall requirements for managing federal awards, however each federal agency may have specific/unique requirements which must be followed. The information below provides some common agency specific requirements that research administrators and principal investigators should be aware of. This list is by no means inclusive of all possible requirements related to federal awards, but represents a selection of agency requirements which may not be broadly understood. It should also be noted that individual awards from the same federal agency may have differing terms and conditions which control each specific agreement, therefore administrators and PIs must be familiar with and follow the terms and conditions of each specific award. 

National Institutes of Health (NIH)

National Science Foundation (NSF)

US Department of Justice/Office of Justice Programs/National Institute of Justice

  • DOJ Grants Financial Guide
  • Items to Remember:
    • When managing awards from OJP/NIJ, administrators and PIs should pay particular attention to ensuring:
      • Award restrictions have been officially/formally removed by an appropriate GAN action before spending on the restricted area(s).
      • Prior Approval for numerous cost items (including pre-award cost and foreign travel) is required
      • Procurement transactions must follow specific requirements. 

US Department of Agriculture/National Institute of Food and Agriculture (NIFA)

  • NIFA Policy Guide
  • Items to Remember:
    • The 2018 Farm Bill maintains an indirect cost provision that limits Indirects to 30 percent of Total Federal Funds Awarded.  However, UCD’s negotiated rate may yield a lesser amount of indirects when when Subawards or other items exempt from indirects under MTDC constitute a significant portion of the budget.  We can only recover the LESSER of the two methods.

Federal Demonstration Partnership

  • Many federal agencies  are participants of the Federal Demonstration Partnership (FDP).  Awards issued with FDP terms and conditions offer administrative flexibilities which significantly reduce the administrative burden associated with managing federal awards. The Prior Approval Matrix is a very useful quick reference tool for awards issued by the federal participants of the FDP. Full agency specific requirement documents are available here.

DHHS Salary Cap

Every year since 1990 Congress has legislatively mandated a provision limiting the direct salary that an individual may receive under an NIH grant. For FY 2012, use of the salary cap was expanded to all agencies under the Department of Health and Human Services, and salaries became restricted to Executive Level II of the Federal Executive Pay scale. Click on the link below to see a summary of the salary cap levels for each year from 1990-present.