Uniform grant guidance (Omnicircular)

On December 26, 2013, the White House Office of Management and Budget (OMB) released its final guidance on “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards.” The guidance, termed here the Omnicircular, supersedes the requirements of various other OMB circulars, including:

OMB Circular A-21, Cost Principles for Educational Institutions,
OMB Circular A-110, Uniform Administrative Requirements, and
OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations.

This new federal regulation will become effective for new federal awards and new funding for existing awards on December 26, 2014. The final regulation is located on the Federal Register website.  Federal agencies are still issuing guidance on the Omnicircular implementation.  

Based on an initial assessment of the Omnicircular, some potential areas of significant change in the new guidance include but may not be limited to:

Procurement standards related to competitive pricing and documentation
Shortened timeline for submission of Financial Reports and Grant Close-out documents (i.e. Final invention/final progress report)
New disclosure of potential conflicts of interests to Federal awarding agencies or pass-through entities
Additional guidance on fixed amount awards regarding pricing, unexpended balances, and reporting to certify that work has been completed

The Medical College of Wisconsin assembled a team to review and address changes that may affect MCW policies, procedures and systems. The team will educate the MCW research community on the new guidance.

The Omnicircular Guidance Core Team consists of the following members:

Kate Thompson, Director of Sponsored Programs and Accounts Receivable
Pam Stanick, Controller
Sandi Stoflet, Research Compliance Manager
Jane Rebro, Compliance Coordinator III
April Haverty, Director of Grants and Contracts
Paulette Pecard, Director of Business Services


May-June 2014: Discovery
June-October 2014: Draft of changes to MCW policies and monitor guidance received from federal agencies and the research community on implementation of the Omnicircular
December 1, 2014: MCW ready to implement changes
December 26, 2014: Federal implementation begins

Please contact Kate Thompson, kmthompson@mcw.edu with any questions.


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