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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:
  1. 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).
  2. 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)).
  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)).
  4. Travel policy (2 CFR §200.474(b)).
  5. 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]).
  6. 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.