New Regulations for Sponsored Projects

The Uniform Guidance, which took effect December 26, 2014, represents the most intense shift in federal research administration policy in 50 years. Released by the White House Office of Management and Budget (OMB) in December 2013, the new guidelines are an undertaking to bring uniformity to the funding regulations provided by 27 federal agencies to their grant recipients. While delivering this level of consistency is no easy task, the intention is to ultimately streamline the requirements for federal awards and reduce administrative burden and financial fraud, waste and abuse.

Since being informed of these changes, Research Affairs Financial Management (RAFM) has made an effort to understand the extent of the changes, how they affect our research programs, and to develop an implementation plan. Our efforts are summarized below:

What is Loma Linda University Health doing regarding implementation?

A Uniform Guidance Committee has been established within Research Affairs Financial Management. This group meets regularly to stay up to date regarding ongoing issues and clarifications related to the Uniform Guidance. LLU also remains engaged as a participating university in the Council on Governmental Relations (COGR) association working to analyze and understand the potential impacts of the UG.

Key Progress of the Uniform Guidance Committee:

  • Launched a new OMB Uniform Guidance webpage
  • Developed a Quick Reference Guide for PIs and Administrators
  • Revised LLUH policies:
    • Closeout of a Sponsored Project
    • Direct Costs on Sponsored Projects
    • Post Award Changes to Sponsored Projects
    • Procurement and Purchasing on Sponsored Projects
    • Subawards and Subrecipient Monitoring
  • LLUH policy revisions in progress:
    • Equipment
    • Effort Reporting
  • Several RAFM SOPs and various other forms are being revised
  • Informational Training Session held (Session PowerPoint slides and Handout)
  • Added the ability to identify awards subject to the UG
  • Added a new account code in Banner Finance to identify participant support costs to be excluded from the F&A base for federal projects.

Learn More about the Changes (External Links)

Current Version of the Uniform Guidance

COFAR's FAQs on Uniform Guidance

COGR Guide to the Uniform Guidance

COGR Summary of Background and Technical Corrections

COGR Implementation Plan for a Major Research University

NCURA Uniform Guidance Webcast Presentation

OMB Policy Statements

Crosswalk from Existing Guidance to Final Guidance

Crosswalk from Final Guidance to Existing Guidance

Cost Principles Comparison Chart and Final Uniform Guidance

Audit Requirements Comparison Chart

Definitions Comparison Chart

Administrative Requirements Comparison Chart

Agency Implementation

NIH Grants Policy Statement (List of Significant Changes)
NSF Proposal and Award Policies and Procedures Guide (List of Significant Changes and Clarifications)


When does the UG become effective?

December 26, 2014

LLUH has elected to ultilize the two year grace period for compliance with the procurement standards under UG. Effective July 1, 2017, procurement of goods and services on federal awards must be in compliance with the UG.

How can I determine if the new guidance applies to my award funding?

Old Guidance Applies to
Awards, Renewed Awards, Supplements
Dated Prior to December 26,2014

New Guidance Applies to
Awards, Renewed Awards, Supplements
Dated On or After December 26, 2014