Research Topic

Federal Financial Regulations

Description

Federal sponsored projects awarded to and administered by the University are to conform to University policies and guidelines and those of the sponsor. Projects where the University is a subawardee are subject to applicable policies of the sponsor providing the funding, as well as the terms and conditions specified by the prime awardee. 

 

Guidance

When the sponsor provides federal funding for the project, either directly or indirectly as pass-through funds, there are specific compliance requirements.

Statutory Requirements

These are created when laws are enacted, and these requirements take precedent over all other policies and regulations related to sponsored projects. A summary of statutory requirements is maintained by the Federal Demonstration Partnership (FDP) in the document entitled  RTC Appendix C National Policy Requirements.

Office of Management and Budget Guidance (OMB) 

This federal agency provides government-wide sponsored project regulatory guidance through: 

  • OMB 2 CFR Part 200 (Uniform Guidance)
    • Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards applies to grants and cooperative agreements and provides a government-wide framework for grants management (note that federal contracts are subject to Federal Acquisition Regulations rather than Uniform Guidance). 

  • Cost Accounting Standards 
    • The Cost Accounting Standards Board, an entity within the U. S. Office of Management and Budget, publishes Cost Accounting Standards (CAS) for commercial contractors and subcontractors. The four Cost Accounting Standards to which universities are subject to through OMB 48 CFR Part 99.05 are the following:

      • Consistency in estimating, accumulating, and reporting costs. This means that proposed budgets should not include costs at a lower level of aggregation for which the University's financial accounting system can account. For example, scientific supplies can be budgeted, but not separate items for reagents, chemicals, and pipettes.

      • Consistency in allocating costs incurred for the same purpose in like circumstances. This requirement is fully described in 16.2 Sponsored Projects Cost Principles.

      • Accounting for Unallowable Costs. This requirement is fully described in 16.2 Sponsored Projects Cost Principles.

      • Cost Accounting Period. This is the University's fiscal year, July 1 through June 30.
Federal Research Terms and Conditions (RTCs)

The Federal Research Terms and Conditions grew out of an initiative by the Federal Demonstration Partnership (FDP), which is a non-profit association of federal agencies, academic research institutions (administrative, faculty and technical), and research policy organizations that works to streamline the administration of federally sponsored research. 

The National Science Foundation (NSF) serves as the official web host of participating agency documents relating to the RTCs. The Federal Research Terms and Conditions are available and hosted by the National Science Foundation (NSF), but they impact all federal agencies.

Federal Acquisition Regulations (FAR)

These are the primary regulations used by federal sponsors to govern contracts for supplies and services, including research services. FAR incorporates OMB 2 CFR Part 200 (Uniform Guidance) for the purpose of defining allowable costs. FAR is not applied to grants and cooperative agreements that are governed by OMB 2 CFR Part 200 (Uniform Guidance), agency grant regulations, or FDP Research Terms and Conditions. Federal contracts typically incorporate all the FAR clauses applicable to a given project.

Note that non-federal projects (i.e. State of Illinois, Private, or other non-federal sponsors) must comply with the applicable sponsor policies and the terms of individual sponsored agreements.

Related Policies

Related Research Topics

Revised Date