Working toward Uniform Guidance
By Pamela Webb, Suzanne Paulson and Nicole Pilman
The Uniform Guidance, which took effect Dec. 26, 2014, represents the most dramatic shift in federal research administration policy in 50 years. Released by the White House Office of Management and Budget (OMB) in December 2013, the new guidelines are an attempt to bring uniformity to the funding regulations provided by 27 federal agencies to their grant recipients. While achieving this level of consistency is no easy task, the goal is ultimately to streamline the requirements for federal awards and reduce administrative burden and financial fraud, waste and abuse.
These numbers should give some idea of the significance and immediate impact of the changes:
- 81 university policies and procedures required review, resulting in dozens of minor changes and several more significant policy changes in the areas of grant closeouts, subawards, procurement and direct charging
- 176 training courses, tutorials, forms and job aids are being reviewed and updated this year
- More than 300 Notice of Grant Award (NOGA) terms were reviewed and updated
All of this may seem abstract to a general reader, but in the world of research funding, it translates to countless real-life impacts on all aspects of research, grant administration, education and training. Of course, the long term goal of the policy changes is to make the federal award process more streamlined and less burdensome. As with any major change, there is short term pain to achieve long term gain.
Over the past year, as primary members of the core implementation team, we have learned a lot about how to successfully prepare for and implement policy changes of this magnitude. Here are our team’s top tips for how to succeed.
1. Be Involved at a National Level
Through participation on national Uniform Guidance committees and workgroups, members of our core team were able to review early versions of the draft guidelines and ultimately help shape the final version. This direct involvement provided our institution with a rare opportunity to help influence the outcome. For example, our team helped create policy interpretations and propose technical corrections and FAQs (both questions and preferred answers!) to OMB to add clarity to the new regulations. OMB was then able to consider whether they agreed with the position taken and where they did, those positions were published as a national resource. Where they did not agree, the process allowed both parties to rapidly understand the other’s position.
Along with other interested constituencies, the higher education community was, through this process, able to convince OMB to delay for one year the implementation of a major change in procurement requirements that would have resulted in delayed science and increased burden for faculty, as well as imposing major electronic system changes. With the added year, the community is now working to gather data to convince OMB and the Council on Financial Assistance Reform of the unintentional negative impact of the new requirement. The ultimate goal is to have the new requirement revised to be more reasonable.
2. Prepare for the Changes Well in Advance
The Uniform Guidance is a 700+ page document. To plan for system and process changes and to provide guidance to principal investigators and others so the research is impacted as minimally as possible, planning had to start early. As soon as OMB announced the new guidelines on Dec. 26, 2013, the U stepped into action, creating the Uniform Guidance steering committee and seven work groups to lead the university’s transition. The university also temporarily hired a skilled departmental administrator to provide an additional resource and a distributed user perspective to the central office staff who had assumed institutional leadership for implementing the new requirements.
3. Communicate Early and Often
Having a clear change management and communications plan is critical for success. Early on we developed a mechanism for communicating about the changes with our primary audience, faculty and grant administrators, including a constantly updated website to provide a central information repository, a series of PI Quick Guides (summaries of the major changes that have the greatest impact on faculty), and presentations at more than 25 meetings across the university. Meeting directly with those impacted by the changes on campus allowed for open dialogue to address related questions and concerns and created a sense of camaraderie and understanding that helped to ease concerns and tensions.
4. Understand and Plan for Operational Challenges
Something that seems like a small, insignificant change could have major “downstream” impacts at the operational level on business processes. The addition of a new, unique Federal Award Identification Number (FAIN) for each award is a good example. Even though they’re required to do so under Uniform Guidance, some agencies haven’t been able to change their electronic systems quickly enough to record the FAIN number on their award notices. And, even though universities are required in turn to report this number to our subcontractors, and also send it back to the federal government, there is currently no place to store that data in our financial system (even if it were included on awards). This seems like a tiny thing that should be noncontroversial, but it requires a system change and transition planning and coordination with multiple internal and external groups.
5. Coordinate with Other System-Wide Changes
Large institutions take a long time to make big changes to their infrastructure and systems. Because the changes are so infrequent yet so widely influential, they can present tremendous opportunities to vastly improve efficiencies and minimize the operational challenges cited above. Understanding and participating in these changes can be very beneficial.
For example, for the past two years, the university has been preparing for a major system-wide upgrade to our human resources, financial and reporting systems (the Enterprise Systems Upgrade Program, or ESUP). While our team has been preparing to implement Uniform Guidance, we have worked closely with the ESUP team to ensure that the upgraded system is responsive to the new regulations. For example, the new Enterprise System will now include a field to input the FAIN number referenced above, significantly minimizing what could have been a major operational challenge.
6. Partner with Other State Institutions
The UG has provided us with a unique opportunity to support and partner with other Minnesota institutions that conduct research, such as private colleges throughout the state. Working with these partners on UG implementation presentations has been a way to build stronger regional research and administration networks that ultimately enhance the depth, breadth and vitality of research and innovation in the state.
Of course, regardless of how much planning and preparation we do, there are bound to be surprises or setbacks. For example, it is taking funding agencies longer than expected to fully implement these changes. While official guidelines are in effect, some agencies are still working to determine how and when they will apply the new rules. When the new rules took effect in December 2014, only one federal agency (National Science Foundation) had fully implemented its final UG plan, leaving award guidelines with the other 26 federal agencies in regulatory limbo and award recipients and grant administrators in a difficult spot. While this is now improving as agencies gradually publish their requirements, this created inconsistencies during the transition period that complicated applications and early awards.
Yet, despite these setbacks, the bulk of our planning work is complete, and we are busily incorporating the UG into our grant administration systems and processes. Researchers and administrators alike should by now be fully aware of how the policy changes impact their work and have a good understanding of how to address changes in current grant proposal processes. Moving forward, we will continue to keep the university community updated and informed through the Uniform Guidance website.
Pamela Webb, associate vice president, Sponsored Projects Administration; Suzanne Paulson, assistant controller; and Nicole Pilman, Uniform Guidance implementation coordinator lead the core team overseeing outreach, education and implementation of Uniform Guidance at the University of Minnesota.