The Office of Management and Budget (OMB) has proposed revisions to Uniform Guidance, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. These federal regulations govern the administration of federal grants and cooperative agreements. The proposed rule was published in the Federal Register on May 29. This is a proposed rule and not final guidance. The federal government is soliciting public comments through July 13 before determining what revisions, if any, will be adopted in a final rule.

CU Boulder intends to contribute to those broader discussions, including by submitting a coordinated response. The Research and Innovation Office (RIO) is actively reviewing the proposal and coordinating with campus partners, the University of Colorado System, peer institutions, national higher education associations, and research advocacy organizations. They also expect many professional organizations and university associations, including the Council on Government Relations (COGR), American Association of Universities (AAU), and Association of Public and Land Grant Universities (APLU), to submit comments on behalf of the research community.

To help inform a coordinated response on behalf of CU Boulder, members of the research and innovation community are invited to share feedback, concerns, questions, recommendations or examples of how the proposed changes could affect your work.

Please complete the form at the link above by Tuesday, June 30. 

Individuals are also welcome to submit comments directly to OMB during the public comment period if they wish to do so. Information about the proposed rule and the federal comment process can be found here.

The proposed rule includes a number of significant proposed changes affecting federal financial assistance and the administration of sponsored research programs. Among other topics, the proposal addresses award oversight and review processes, grant administration requirements, allowable costs, foreign collaborations, research integrity considerations, and other aspects of federally funded research. Here is a summary of some of the key material revisions proposed to the Uniform Guidance.

Importantly, the current proposed Uniform Guidance rule does not establish a government-wide cap on negotiated indirect cost rates. However, the rule states that all else being equal, preference for awards should be given to institutions with lower IDC rates. Existing regulations continue to require federal agencies to recognize federally negotiated indirect cost rates except in limited circumstances authorized by statute or regulation.

Many aspects of the proposal raise important questions for the research community. CU Boulder is actively engaged, monitoring developments closely, and advocating for the continued strength and effectiveness of the research enterprise.

Thank you for your continued engagement and partnership.