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Uniform Guidance changes will impact sponsored projects

Sunday, November 29, 2020

The Office of Management and Budget is revising sections of OMB Guidance for Grants and Agreements, also known as Uniform Guidance (2 CFR 200). These revisions were effective Nov. 12, 2020, except for the amendments to §200.216 and §200.340, which were effective on Aug. 13, 2020.

Following are the most impactful changes for your sponsored projects:

Increase in micro-purchase threshold (§200.320)

Threshold for micro-purchases increases from $10,000 to $50,000.  The purchase of goods or services with an aggregate dollar amount which does not exceed $50,000 are considered “micro-purchases.” Micro-purchases may be awarded without soliciting competitive quotations, meaning KUCR purchases of $50,000 or less will no longer require three competitive quotes.    

Questions? Contact KUCR Purchasing at kucrpurchasing@lists.ku.edu.

§200.216 Prohibition on certain telecommunications and video surveillance services or equipment; §200.471 Telecommunications and video surveillance costs

New regulations disallow contracting or purchasing goods and services from certain foreign entities due to national security concerns. This list currently includes Huawei Technologies Company, ZTE Corporation, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities).

Sponsored Project Costs

  • §200.461 Publication costs
  • §200.458 Pre-award costs

Close-Out/Final Reporting (§200.344-§200.345) 

Recipients now have 120 calendar days after the end date of the period of performance to submit all financial, performance and other reports as required by the terms and conditions of the federal award. This is still 90 days for awards on which KU/KUCR is a subrecipient.

Termination (§200.340-§200.342)

Termination “for cause" (poor performance) has been deleted and now states that awards may be terminated in whole or in part “to the greatest extent authorized by law, if an award no longer effectuates the program goals or agency priorities.”

Additionally termination by a federal agency may occur if the federal award is terminated for the non-federal entity’s material failure to comply with the U.S. Constitution, federal statutes, regulations, or terms and conditions of the federal award.

All sponsors will implement these changes differently — some issuing updated terms and conditions and others implementing at next supplement or competitive cycle. Budget summaries will be issued if sponsors issue term and condition changes.

If you have questions, please contact pas@ku.edu or find more information on the Uniform Guidance page of the KU Research website.