Uniform Administrative Requirements for Library Services and
Technology Act Grant Applicants
What are
Uniform Administrative Requirements?
The
federal Office of Management and Budget's (OMB) Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal
Awards (commonly called "Uniform Grant Guidance" or UGG) was
officially implemented in December 2014 by the Council on Financial Assistance
Reform (COFAR). The Uniform Guidance – a "government-wide framework for
grants management" – synthesizes and supersedes guidance from earlier OMB
circulars[1].
The reforms that comprise the Uniform Guidance aim to reduce the administrative
burden on award recipients and, at the same time, guard against the risk of
waste and misuse of Federal funds. Among other things, the OMB's Uniform
Guidance does the following:
- Removes previous
guidance that is conflicting and establishes standard language;
- Directs the focus of
audits on areas that have been identified as at risk for waste, fraud and
abuse;
- Lays the groundwork for
Federal agencies to standardize the processing of data;
- Clarifies and updates
cost reporting guidelines for award recipients.
[1] The
Guidance was drawn from OMB Circulars A–21, A–87, A–110, and A–122 (which have
been placed in past OMB guidances); Circulars A–89, A–102, and A–133; and the
guidance in Circular A–50 on Single Audit Act follow-up.
New Required
Library Services and Technology Act Policies and Procedures:
To
comply with the federal Uniform Administrative Requirements for grants (2 CFR
§200.300 - §200.345), all LSTA Grant applicants must have a written:
- Cash management procedure or policy which establish LSTA
fund controls and accountability, including written procedures for determining
the allowabilty of costs under the terms and conditions of the LSTA award (2
CFR §200.302(b)(6), §200.302(b)(7), §200.305).
- Bid and procurement procedure or policy that establish
standards and controls for the purchase of all goods and services, including
written procedures for the evaluation of the proposals received and for
selecting awardees (2 CFR §200.319(c), §200.320(d)(3)).
- Conflict of interest policy which governs the
actions of its employees or board members who engage in the selection, award
and administration of contracts, including disciplinary actions should the
policy be violated (2 CFR §200.318(c)).
- Travel policy (2 CFR §200.474(b)).
- Compensation and fringe benefit policy if federal funds are
used for compensation and fringe benefits (2 CFR §200.430(a), §200.431(a),
§200.464 [Relocation Costs of Employees]).
- Indirect cost rate development procedure if an indirect cost
rate other than 10 percent has been negotiated directly with the federal
government. (2 CFR §200.414, §200.331(a)(4), Appendices).
Sample Policies
Click on the Word or PDF text below to view sample policies in
that version. They are presented for reference purposes and not as legal
advice. When faced with a question concerning appropriate policies or the
Uniform Grants Guidance libraries should seek the advice of their own legal
counsel.