Uniform Guidance Revisions & Stanford's Implementation

If the University decides to implement this increase...

• Advise the Stanford Research Administration community to use the $50K threshold 
• Update SeRA, ORA Budget Tool, and ORA Budget Justification Template
• Update policies
• Update Stanford's IDC proposal

ONR has approved implementation of accounting changes with effect from new rate agreement -  09/01/2026 

University decision to be made if this increase will be implemented - more information to come!

If the University decides to implement this increase...

• Update equipment policies
• Implement new threshold in Sunflower and Oracle FA 
• Update DS-2 
• Update Depreciation projections for IDC proposal 
• Update Stanford's IDC proposal

ONR has approved implementation of accounting changes with effect from new rate agreement -  09/01/2026 

University decision to be made if this increase will be implemented - more information to come!

200.113 Mandatory disclosures

(This section has been refined to match FAR and expanded to include the requirement to report when the recipient has “credible evidence of the commission of a violation.” Conflict of interest is added to what must be reported to federal sponsors, and the section incorporates the False Claims Act (31 U.S.C. 3729-3733). Disclosures must be made in writing to the Office of the Inspector General for the agency.)

200.201 Use of grants, cooperative agreements, fixed amount awards, and contracts

• 200.201 (b)(1) replaced “adequate” with “accurate cost, historical or unit pricing data to establish a fixed amount budget…” (still based on “reasonable estimate of actual cost”) and added that federal funding is determined by “subrecipient’s proposal, available pricing data, and subpart E.”
  • Replaced “there is no governmental review” of actual costs incurred by the recipient with “There is no expected routine monitoring of actual costs incurred... Therefore, no financial reporting is required.”
• 200.201 (b)(2) Added back fixed amount award must not be used in programs that require cost sharing (originally was removed).
• 200.201 (b)(3) Added requirements of 200.307 (Program Income) do not apply to fixed amount awards unless specified in the Federal award. 
• 200.201 (b)(4) At the end of the fixed amount award, must certify in writing that the project was completed “or the level of effort was expended…as agreed to in Federal Award or identify those activities not completed, and that all expenditures were incurred in accordance with §200.403.” 
• 200.201 (b)(6) Added §200.308(f)(1-3,6-8,10) and §200.333: Prior approval for changes in scope, key personnel (specified by name or position), PI disengagement of more than 3 months or 25% reduction in time, “Subaward activities not proposed in the application and approved in the Federal award” (NEW) – but clarifies a change in subrecipient does not require prior approval unless specified in award/subaward

200.215 Never contract with the enemy

(Federal agencies, recipients, and subrecipients are subject to the guidance implementing Never Contract with the Enemy in 2 CFR part 183.)

200.216 Prohibition on certain telecommunications and video surveillance equipment or services

(Certifying that it will comply with the prohibition on covered telecommunications equipment and services in this section)

200.217 Whistleblower protections 

(The recipient and subrecipient must inform their employees in writing of employee whistleblower rights and protections under 41 U.S.C. 4712.)

200.300 Statutory and national policy requirements 

(Removed (b) The non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR parts 25 and 170. ) (Added ensure that the award is administered in a way that does not unlawfully discriminate based on sexual orientation or gender identity) (must take account of the heightened constitutional scrutiny that may apply under the Constitution’s Equal Protection guarantee)

200.306 Cost sharing 

(k) For institutions of higher education (IHE), voluntary uncommitted cost sharing should be treated differently from mandatory or voluntary committed cost sharing. Voluntary uncommitted cost sharing should not be included in the organized research base for computing the indirect cost rate or reflected in any allocation of indirect costs. Voluntary uncommitted cost sharing includes faculty-donated additional time above that agreed to as part of the award.

200.308 Revision of budget and program plans 

Revisions requiring prior approval (6)Subaward activities not proposed in the application and approved in the Federal award. (9) Transferring funds between the construction and non-construction work under a Federal award. (10) A no-cost extension of the period of performance, other than any one-time extension authorized by the Federal agency

200.311 Real property 

Encumbrance of easements etc., Appraisal of real property by an independent appraiser.

Currently, specific authorization is obtained from sponsors for direct charging rental costs of real property and equipment to sponsored awards.

The eliminated sections will not impact the current process.

200.313 Equipment 

• (a) Title 
• (b) General 
• (d) Management Requirements 
• (e)  Disposition 
• (f) Equipment Retention

Same as current requirement 

If the $10K threshold is adopted by SUI, the soonest it could be implemented would be FY27. 

Agencies may differ in their related use of "conditional title" which we will need to monitor.

200.314 Supplies 

When there is a residual inventory of unused supplies exceeding $10,000 in aggregate value at the end of the period of performance, and the supplies are not needed for any other Federal award, the recipient or subrecipient may retain or sell the unused supplies.

Advise the Stanford Research Administration community of increase in threshold to $10,000.

 Monitoring residual supplies

200.315 Intangible property 

(b) The Federal agency reserves a royalty-free, nonexclusive, and irrevocable right to reproduce, publish, or otherwise use the work for Federal purposes, and to authorize others to do so. This includes the right to require recipients and subrecipients to make such works available through agency-designated public access repositories. (f) Federal agencies should work with recipients to maximize public access to Federally funded research results and data in a manner that protects data providers’ confidentiality, privacy, and security. Agencies should provide guidance to recipients to make restricted-access data available through a variety of mechanisms. FOIA may not be the most appropriate mechanism for providing access to intangible property, including Federally funded research results and data.

(b) terms included in award agreements

(f) This is a requirement for federal agencies.  Current SU policies in place include Data Privacy policy, Information Security policy, Minimum Privacy policy that are available to investigators to meet open access requirements.  SU will follow agency specific guidance to make restricted access data available to the extent we can.

200.328 Financial reporting 

Split into 4 sections a, b, c, d Data Elements, Frequency, Due date, FFR due date

200.331 Subrecipient and contractor determinations 

The pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract. In making this determination, the substance of the relationship is more important than the form of the agreement.

200.332 Requirements for pass-through entities 

Verify that the subrecipient is not excluded or disqualified Evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward Ensure that the subrecipient takes action on all significant developments that negatively affect the subaward

200.333 Fixed amount subawards 

Increase Fixed Amount Subawards threshold to $500,000

200.344 Closeout 

The recipient must submit a revised final financial report when applicable indirect cost rates have been finalized. The Federal agency is authorized to mutually agree with the recipient to close an award using the current or most recently negotiated rate

200.403 Factors affecting allowability of costs 

(h) Administrative closeout costs may be incurred until the due date of the final report(s). If incurred, these costs must be liquidated prior to the due date of the final report(s) and charged to the final budget period of the award unless otherwise specified by the Federal agency.

200.407 Prior written approval (prior approval requirement removed) 

• (a) Use of Fixed Amount Award (item (b) (5) - Change of PI and scope only) - 200.201 
• (e) Real Property –200.311 
• (f) Equipment –200.313 
• (h) Direct Costs, 200.413 paragraph (c) (3)-Direct administrative staff 
• (k) Entertainment Costs - 200.438 
• (r) Memberships, subscriptions, and professional activity costs 200.454 (c) 
• (t) Participant Costs - 200.456 
• (w) Selling and Marketing costs - 200.467 
• (x) Taxes - 200.470

200.414 Indirect Costs 

(f) De minimis rate. Recipients and subrecipients that do not have a current Federal negotiated indirect cost rate (including provisional) rate may elect to charge a de minimis rate of up to 15 percent of modified total direct costs (MTDC).

200.415 Required certifications 

(b) Subrecipients under the Federal award must certify to the pass-through entity whenever applying for funds, requesting payment, and submitting financial reports: “I certify to the best of my knowledge nd belief that the information provided herein is true, complete, and accurate. I am aware that the provision of false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil, or administrative consequences including, but not limited to violations of U.S. Code Title 18, Sections 2, 1001, 1343 and Title 31, Sections 3729-3730 and 3801-3812.”

200.419 Cost accounting standards

Eliminate the requirement for DS-2 (formerly 200.419 (b)) 

(b) (1), (2), (3), (4), (5), (6) are all eliminated

200.431 Compensation - Fringe Benefits 

(b) (3) (i) – NEW Subsection – Leave - When a recipient or subrecipient uses the cash basis of accounting, the cost of leave is recognized in the period that the leave is taken and paid for.

200.431 Compensation - Fringe Benefits 

c(g) (6) (v) – NEW Subsection – Unfunded Pension Costs Specifically, the recipient or subrecipient may not charge unfunded pension costs directly to a Federal award if those unfunded pension costs are related to compensation not allocable to that award.

200.431 Compensation - Fringe Benefits 

(h)(5) - NEW Subsection – Unfunded Postretirement Health  Specifically, the recipient or subrecipient may not charge unfunded PRHP costs directly to a Federal award if those unfunded PRHP costs are related to compensation not allocable to that award.

200.438 Entertainment and prizes 

(b) Prizes. Costs of prizes or challenges are allowable if they have a specific and direct programmatic purpose and are included in the Federal award.

200.439 Equipment and other capital expenditures 

(b) (2) Capital expenditures for special purpose equipment are allowable as direct costs, provided that items with a unit cost of $10,000 or more have the prior written approval of the Federal agency or pass-through entity.

200.468 Specialized service facilities 

(a) These costs include charges for facilities such as computing facilities, wind tunnels, and reactors.

200.472 Termination and standard closeout costs 

(a) Termination Costs: (d) These rental costs may include the cost of alterations of the leased property and the cost of reasonable restoration required by the lease, provided the alterations were necessary for the performance of the Federal award.

(b) Closeout Costs. Administrative costs associated with the closeout activities of a Federal award are allowable. The recipient or subrecipient may charge the Federal award during the closeout for the necessary administrative costs of that federal award (for example, salaries of personnel preparing final reports, publication and printing costs, costs associated with the disposition of equipment and property, and related indirect costs). These costs may be incurred until the due date of the final report(s). If incurred, these costs must be liquidated prior to the due date of the final report(s) and charged to the final budget period of the award unless otherwise specified by the Federal agency.

Post-Award process: will notify post award team. Will try to incorporate the expenses in the closeout process and will mitigate it on case-by-case basis due to the constraints of final draw/payment.

PMO needs to be aware relative to costs associated with disposition of equipment.

200.501 Audit requirements 

(a) Audit required. A non-Federal entity that expends $1,000,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part. (b) Single audit. A non-Federal entity that expends $1,000,000 or more in Federal awards during the non-Federal entity's fiscal year must have a single audit conducted in accordance with § 200.514 except when it elects to have a program-specific audit conducted in accordance with paragraph (c) or (d) of this section.

Currently in place for Stanford annual UG audit 

Pre-award - anticipating implementation to reflect this effective for a sub entity's first full FY after 10/1/2024; Sub Team will determine this on a case-by-case basis; and watch agency guidance for how this impacts single audit requirements for entities not subject to UG (i.e., HHS agencies).