The following is a list of open issues – regulations in the guidance that are being questioned by COGR or are otherwise not yet resolved.
Research Terms and Conditions (RTC) expire on 12/26/2014. FDP is working with federal officials to secure new or existing RTC terms. The organization prepared a white paper on Standard Terms and Conditions for the April 14, 2014 joint FDP/COGR/Federal Partners Meeting. (Page 8 of the White Papers).
General Procurement Standards (200.318-320). UG standards represent a potential administrative burden for IHE’s (Institutions of Higher Education). (See the changes related to procurement.) COGR has submitted a request to OMB to review the Procurement and Terminal Leave issues (Read the letter dated 6/17/2014.) The University of Maryland Baltimore County will continue to follow the procurement requirement of OMB Circular A-110 and will utilize the grace period allowed in the Uniform Guidance. For more information on UMBC’s procurement policies, go to http://procurement.umbc.edu/.
Most Recent COGR Requests for Clarification: Listed here are three recent letters that COGR has sent to the COFAR applicable to the OMB Uniform Guidance: 1) September 26, 2014 – request to clarify the definition of MTDC and use of the term “subcontract” – click here is for the letter; 2) October 9, 2014 – request to incorporate technical corrections into the final version of the Uniform Guidance – click here for the letter; and 3) October 10, 2014 – request to change the trigger for DS-2 submission from $50 million of federal awards to $50 million of CAS-covered contracts – click here for the letter.