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2 CFR Part 200 terms and conditions Vargas, Pamela (08 Oct 2014 07:30 EST)
Re: 2 CFR Part 200 terms and conditions Lawrence Waxler (08 Oct 2014 08:14 EST)
Re: 2 CFR Part 200 terms and conditions Vargas, Pamela (09 Oct 2014 14:13 EST)
Re: 2 CFR Part 200 terms and conditions Tracy Eisenhower (09 Oct 2014 17:31 EST)
Re: 2 CFR Part 200 terms and conditions Watkins-Wendell,Kathryn A (09 Oct 2014 18:30 EST)
Re: 2 CFR Part 200 terms and conditions Gray, Barbara (10 Oct 2014 09:15 EST)
Re: 2 CFR Part 200 terms and conditions McClure, Christine Lynn (07 Nov 2014 09:35 EST)

Re: 2 CFR Part 200 terms and conditions McClure, Christine Lynn 07 Nov 2014 09:35 EST

We have received awards that incorporated the UG.  We are still grappling with how to manage this especially with the issuance of subawards that are part of those awards that have incorporated the UG.
Christine

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Gray, Barbara
Sent: Friday, October 10, 2014 10:16 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] 2 CFR Part 200 terms and conditions

Katie,
Have you had any discussions about any impacts of applying the UG to all your institution's grants after 12/26 when some of those may involve subawards to other institutions that are not planning to do the same?  Will you allow your subawardees to continue existing agreements under A-110/21/133 or will you require that they also become subject to UG on 12/26?  What kinds of conflicts and potential audit issues might this cause, especially if the subawardee is another institution that elects not to apply to UG to all existing awards as of 12/26?  Are there other potential issues for subawardees that are not IHEs?  For instance, if you issued a subaward to a non-profit that didn't have a negotiated F&A rate and so budgeted $0 for F&A, will you now allow them to add the de minimis 10% F&A for remaining years in the subaward?  I'm not advocating for one stance or the other; just trying to figure out what issues we might have if institutions who pass funds back and forth operatio!
 nalize the UG differently.
bg

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-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Watkins-Wendell,Kathryn A
Sent: Thursday, October 09, 2014 7:30 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] 2 CFR Part 200 terms and conditions

Plante Moran did a presentation for the NE Ohio Uniform Guidance group.  While they didn't say anything about implementing prior to 12/26, they did tell us that the feds are allowing grantees to use uniform guidance 2 CFR 200 for all grants once the CFR is implemented, not just grants issued after 12/26.  Our institutions were all concerned about managing under two sets of regs.  So this really eased our minds.  but we are not planning to implement anything new prior to 12/26.  we will manage all grants in accordance with 2 cfr 200 after 12/26.

Katie Watkins-Wendell
Sent from my iPad

> On Oct 9, 2014, at 6:13 PM, "Tracy Eisenhower" <xxxxxx@IUP.EDU> wrote:
>
> Pam,
>
> I would contact the agency or program officer and get confirmation.
> and I know I would appreciate an update on anything you learn!
>
> Tracy
>
> Tracy Eisenhower, M.A., CRA
> IUP Research Institute
>
> Sr. Grant & Contract Specialist
> 1179 Grant St.
> Indiana, PA  15701
> 724-357-1915 (Office)
>
>> On 10/9/2014 3:13 PM, Vargas, Pamela wrote:
>> Just following up on this request.  In response to Larry's reply, yes, we are aware that the requirements are to apply to awards made on or after December 26.... and yes, my colleague did receive something that already referenced 2 CFR Part 200.
>>
>> I was as surprised as Larry was when I heard about it.
>>
>> They have requested that I not release the name of the agency.
>>
>> Has anyone else had this experience, or can you see problems with accepting the terms before December 26?
>>
>> Many thanks!
>>
>> Pam
>>
>>
>>
>> Pamela A. Krauser Vargas
>> Kutztown University
>>
>> Phone 484-646-4340
>>
>>
>> -----Original Message-----
>> From: Research Administration List
>> [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Lawrence
>> Waxler
>> Sent: Wednesday, October 08, 2014 9:15 AM
>> To: xxxxxx@lists.healthresearch.org
>> Subject: Re: [RESADM-L] 2 CFR Part 200 terms and conditions
>>
>> Pam,
>>
>> It is my understanding that the implementation of the new requirements will apply to awards made after December 26, 2014, not before.
>>
>> If anyone in grant-land has seen otherwise, I would be shocked!
>>
>> Larry
>>
>> ~~~~~~~~~~~~~~~~~~~~~~~
>> Larry Waxler, Director
>> Office of Sponsored Programs
>> University of Southern Maine
>> 1 Chamberlain Avenue
>> P.O. Box 9300
>> Portland, ME  04104-9300
>> Telephone: 207-780-4413
>> Telefax: 207-780-4927
>>
>>
>>
>>
>>>>> "Vargas, Pamela" <xxxxxx@KUTZTOWN.EDU> 10/8/2014 8:30 AM >>>
>> Hi, everyone!
>>
>> I am posting for a colleague who would like to know if any universities have received award notices that incorporate the new 2 CFR Part 200 into the terms and conditions, and, if so, did you  accept them?
>>
>> Also, can anyone out there site any down sides to accepting them before December 26?
>>
>> Thanks!
>>
>> Pam
>>
>> Pamela A. Krauser Vargas
>> Kutztown University
>>
>> Phone 484-646-4340
>> xxxxxx@kutztown.edu<mailto:xxxxxx@kutztown.edu>
>>
>>
>>
>>
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 Instructions on how to use the RESADM-L Mailing List, including  subscription information and a web-searchable archive, are available  via our web site at http://www.healthresearch.org (click on the  "LISTSERV" link in the upper right corner)

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 Instructions on how to use the RESADM-L Mailing List, including  subscription information and a web-searchable archive, are available  via our web site at http://www.healthresearch.org (click on the  "LISTSERV" link in the upper right corner)

 A link directly to helpful tips:  http://tinyurl.com/resadm-l-help ======================================================================

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.healthresearch.org (click on the
 "LISTSERV" link in the upper right corner)

 A link directly to helpful tips:  http://tinyurl.com/resadm-l-help
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