On December 26, 2013, the Office of Management and Budget (OMB) issued the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (also known as the “Uniform Guidance” or 2 CFR 200). The Uniform Guidance consolidates, streamlines and supersedes the eight existing OMB Circulars including Circular A-21, A-110, and A-133. Included in this new guidance are definitions, uniform administrative requirements (preaward & postaward), cost principles and audit requirements. The new guidance, which will affect all federally funded grants and contracts, will take effect on December 26, 2014.

In response to this release the University of Connecticut has set up a University-wide Uniform Guidance Task Force spanning both the Storrs and Farmington campuses. The Task Force includes representatives from central administration and various UConn departments active in research to coordinate the implementation of the Uniform Guidance. Among the Task Force’s goals is to keep the UConn community informed about the changes that will affect PIs, researchers, department administrators and others involved with sponsored projects. This webpage will provide updated information specific to Uniform Guidance implementation and will post new material once it becomes available.

Navigating the Uniform Guidance

The Uniform Guidance is broken down into the following subparts:

Part I – Objectives
Part II – Major Policy Reforms
Subpart A (200.0 – 200.99) – Acronyms and Definitions
Subpart B (100.200 – 200.113) – General Provisions
Subpart C (200.200 – 200.211) – Preaward Requirements
Subpart D (200.300 – 200.345) – Postaward Requirements
Subpart E (200.400 – 200.475) – Cost Principles
Subpart F* (200.500 – 200.521) – Audit Requirements

*Subpart F will apply to university audits beginning the fiscal year starting after the Uniform Guidance takes effect on December 26, 2014 (July 1, 2015).

Revisions to the Uniform Guidance can be found at the Federal Register Guidance for Grants and Agreements-February 22, 2021

What is UConn Doing to Implement the Uniform Guidance?

In preparation for the December 26, 2014 implementation date, UConn (all campuses) have created a subcommittee to review and catalog changes that may be required due to the new Uniform Guidance.

The group is responsible for determining the impact of the new regulations to existing policy and process, creating new training materials and revising policies where needed, and ensuring broad and effective communication strategies.

Training Materials

• PowerPoint Slides
• Implementation Guide for Principal Investigators and Department Administrators and Coverletter
• Subaward Determination Guidance
• Federal Cost Principles Training

Uniform Guidance Timeline

Resources

• Council on Financial Assistance Reform (COFAR)
  • COFAR FAQS (July 2017)
• Federal Demonstration Partnership (FDP)
  • Meeting Presentations from May 2014
  • Meeting Presentations from September 2014
• Council on Governmental Relations (COGR)
  • COGR Version 1 response to Uniform Guidance (April 24, 2014)
  • COGR Version 2 Guide to OMB Uniform Guidance (September 17, 2014)
  • COGR Implementation and Readiness Guide for the OMB Uniform Guidance (December 12, 2014)
  • COGR Implementation and Readiness Guide for the OMB Uniform Guidance (November 17, 2020)
• Federal Register
  • Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
• National Science Foundation (NSF)
  • NSF Grant General Conditions (GC-1)
  • Financial & Administrative Terms and Conditions (CA-FATC)
• National Institute of Health (NIH)
  • NIH FAQs on the Uniform Guidance and NIH Interim Grant Conditions
  • NIH Interim Grant General Conditions
• Department of Education
  • Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
  • ED FAQs
  • Dept of Ed Webcast PowerPoint
• NCURA
  • NCURA Webcast – Uniform Guidance: The Challenges of Implementation – PowerPoint

The Other Direct Costs (or Other Costs) budget category includes those costs that are not appropriately included in other cost categories, or as required by the sponsor’s budget form. Generally, such costs include animal per diem costs (the cost of animals should be listed as a supply), human subject honoraria, publication charges, subawards, computer time, maintenance and other service agreements/charges, space rental, consultants, alterations or renovations, equipment rental, etc. Many of these cost categories are discussed below.

Equipment

Equipment is defined as tangible, non-expendable, personal property having an anticipated life of one year or more with a unit acquisition cost of $5,000 or greater. Equipment includes, but is not limited to, furnishings, scientific apparatus, machinery, library volumes, artwork, motor vehicles, boats and livestock. Proposers should identify the individual pieces of equipment requested, their importance to the project, and why existing equipment does not suffice.  Price quotes or the basis for projected prices may be required for larger pieces of equipment. Equipment costs are excluded from the Modified Total Direct Cost (MTDC) “base,” or the dollar amount to which the indirect cost rate is applied; see Indirect Costs below. For additional information, including equipment definitions, please see the Accounting website.

Travel

Travel costs are classified as those expenses for transportation, lodging, subsistence and related items incurred by employees who are traveling on official University business. Domestic and foreign travel should be separately identified. Unless otherwise stated by the sponsor, domestic travel is considered to be travel among any of the 50 United States, its possessions and territories, and Canada. Foreign travel is classified as travel outside these areas. Travel justification should include who is traveling, where, the purpose of the trip, the number of trips, the costs for the air fare, per diem, lodging, car rental and other costs associated with the travel. For more general information see the UConn Procurement Travel website. For information about international travel, please see the OVPR’s International Travel page.

Materials and Supplies

Supplies and materials are any consumable item having an acquisition unit cost of less than $5,000.  These costs should be project-specific, reasonable and based on actual or historical use. Unless required by the sponsor, it is not necessary to break down each individual item, but a general description and amount by general classification should be provided (e.g. glassware, test tubes, or chemicals).

Publication Costs

Publication costs consist of the documenting, preparing, publishing, disseminating, page and reprint charges, and sharing of project findings and supporting material. Budgets should be based on actual experience with an inflation factor built in for future years.

Subawards/Subcontracts

Subrecipient agreements, either subcontracts or subawards (both may be referred to as “subawards”) are a mechanism for passing funding provided by a prime sponsor through to a subrecipient for the purpose of carrying out a portion of the scope of work of the project. If a portion of the work is to be completed by another institution, a subrecipient proposal, including a statement of work, budget, budget justification and Negotiated Indirect Cost Rate Agreement is required. For awards made on or after July 1, 2025, the Modified Total Direct Cost base includes the first $50,000 of each sub-contract (prior threshold $25,000); see Indirect Costs below.

Consultants

Consultants are independent contractors, not employees, who provide a service that cannot be performed satisfactorily by existing University personnel during the performance of the project. A consultant letter of intent that includes the period of service or number of days on the project, professional fee/rate, and travel and other related expenses should be provided to Sponsored Program Services.

Animal Care Costs

Animal costs should reflect the type of animal, the number of animals and the unit cost per animal. Per diem costs should list the number of days of per diem.  The Animal Care Services Information for Grant Preparation page includes current per diem rates can be found on the Animal Care Services website. The current indirect cost rate should be applied to Animal Care Costs.

Participant Support Costs

Participant Support Costs typically support training, conference, and workshop activities, and may include travel, stipend, and subsistence for participants. As defined in 2 CFR 200.1 “Definitions”, participant support costs are “direct costs that support participants and their involvement in a Federal award, such as stipends, subsistence allowances, travel allowances, registration fees, and per diem paid directly to or on behalf of participants.” Typically, Participant Support Costs are incurred for projects that include an education or outreach component. The funding opportunity announcement (FOA) will indicate when these expenses are allowable as direct costs to the project. 

• Participants ARE: individuals whose primary purpose of attending an event is learning or receiving training and who receive a stipend, per diem or subsistence allowance rather than a salary and fringe benefits. Participants do not perform work or services for the project or program other than for their own benefit. Participants are not required to deliver anything or provide any service to UConn in return for the support.
• Participants ARE NOT: UConn employees; students or project staff members receiving compensation directly or indirectly from the grant; research subjects receiving incentive payments; or recipients of any compensation from any other federal government source while participating in the project (applies only to federal grants).
• Participant Support Costs are direct costs for items such as stipends or subsistence allowances, travel allowances and registration fees paid to or on behalf of participants or trainees in connection with meetings, conferences, symposia or training projects.

Participant Support Costs are excluded from the MTDC base (see Indirect Costs below), and should not be confused with Human Subject Payments.  Payments or gifts given to research subjects in exchange for study participation are included in the MTDC base (see Indirect Costs below).

All Other Direct Costs

Indicate any other project-related expenses, such as postage, long-distance telephone charges, equipment maintenance, boat charges, computer services, participant stipends and human subject costs.  The budget justification for these costs should include the number of units and cost per unit.

07/24/2025

The University’s Indirect Cost Rate Agreement, negotiated with the Department of Health and Human Services and dated 9/27/24: Indirect Cost Rate Agreement.

Indirect costs are those costs that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project. The recovery of indirect costs reimburses UConn for actual costs incurred by support functions to sponsored programs at the University. The University negotiates its rate, which is based on Modified Total Direct Costs (MTDC), with the Department of Health & Human Services.

It is the policy of the University to collect full indirect costs at the federally negotiated rates from all funding sources whenever possible.  Occasionally, sponsors may specify an indirect cost policy inconsistent with the University’s negotiated rate, and budgets should be prepared using the sponsor rate. Only the Office of the Vice President for Research has the authority to accept a reimbursement rate other than the negotiated rate.

Effective 9/27/24:

• UConn’s Modified Total Direct Cost (MTDC) base has been updated to raise the threshold for inclusion of subaward dollars from $25,000 to $50,000, effective 7/1/25 (see below). As a result, the first $50,000 of the total amount of each subaward budgeted for inclusion after 7/1/25 should be included in the base when calculating indirect costs using an MTDC base (see Definition below).
• Current awards will continue to utilize the IDC rate in effect at the time of the initial award;
• New awards may continue to use the proposed rate (if lower), if allowed by the sponsor.

Indirect Cost Rates

*Indirect costs are calculated on Modified Total Direct Cost (MTDC) which is Direct Costs minus certain exclusions. Direct Costs include salary, fringe benefits, materials and supplies, travel, and the first $50,000 of each subcontract (after 7/1/25).

Exclusions include equipment over $5,000**, rent, fellowships, tuition, participant support costs and subcontract amounts beyond the first $50,000 for each subcontract (after 7/1/25).

**In order to be consistent with State classification standards, the dollar threshold for capitalization of equipment at UConn is $5,000.

Modified Total Direct Cost (MTDC) Base Definition, Awards Beginning 7/1/2025 and Later:

Modified total direct costs, consisting of all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $50,000 of each subaward (regardless of the period of performance of the subawards under the award). Modified total direct costs shall exclude equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships and fellowships, participant support costs, and the portion of each subaward in excess of $50,000. Other items may only be excluded when necessary to avoid a serious inequity in the distribution of indirect costs, and with the approval of the cognizant agency for indirect costs.

The following language should be used in all proposal budget justifications that include indirect costs using rates listed on the rate agreement, with adjustments for the budget periods being proposed:

“Indirect costs are based on University of Connecticut’s federally negotiated rates and are applied at a rate of 62.5% in Year 1, and 63.5% in Years 2-5 applied to a modified total direct cost (MTDC) base. Any applicable capital equipment, participant support, and subaward costs from the University of Connecticut to other organizations after the first $50,000 are excluded from the MTDC base calculation. The rates and exclusions are consistent with the University’s federally negotiated indirect cost rate agreement (DHHS, 9/27/2024).”

Total Direct Cost (TDC) Base:

When applying the indirect cost rate to a Total Direct Cost base, no exclusions apply; the budget justification language should be revised to correspond.

Off-Campus Rate

For all activities performed in facilities not owned by the institution and to which rent is directly allocated to the project(s), the off campus rate will apply. Grants or contracts will not be subject to more than one indirect cost rate.  If more than 50% of a project is performed off campus, the off campus rate should be applied to the entire project.

The off campus indirect cost rate can be budgeted as follows:

• If rent is directly charged to the project.
• If more than 50% of all program activities are performed off campus.   (with written confirmation from the PI).
• If the sponsor specifically requires the off-campus rate per the solicitation.

The on-campus rate is normally applied whenever the University leases or pays for space costs that are not direct charged to a grant or contract.

If you have questions, please contact your SPS Grants/Contracts Specialist.

Sponsor-Stated Limits

When the University collects indirect costs at less than the full federally negotiated rates,  indirect costs are charged to Total Direct Costs (including equipment, participant support costs, subcontracts, etc.,)  unless otherwise stated in the sponsor guidelines.

Funding from Connecticut State agency appropriations and local municipalities are charged a current reduced rate of 20%.  Indirect costs should be charged to Total Direct Costs.  If the Originating Sponsor is non-State, the full rate allowable by the originating/prime sponsor should be applied.

Reduction of F&A on Projects Having a Total Cost of $50k or Less

To allow for more buying power on small sponsored projects and to help foster smaller awards which may lead to additional funding, indirect costs on new awards received after October 1, 2017 with total costs of $50,000 or less, will be reduced to 20% or the difference between the full indirect cost rate and 20% will be distributed to the investigators indirect cost account.  Indirect costs are charged to Total Direct Costs (TDC) or Modified Total Direct Costs (MTDC),  as required by the specific sponsor or solicitation.

Sponsored Program Services (SPS) has developed guidance and FAQs on how this program is implemented.

Consistent Treatment of Costs:

Costs must be treated consistently.  Consistent treatment means that similar costs must be treated uniformly in the same manner as either a direct cost or as indirect costs.  Certain types of costs, such as the salaries of administrative and clerical staff, office supplies, and postage are normally treated as indirect costs; therefore, the same types of costs cannot be charged directly to federally sponsored agreements.

Definition

Cost sharing or matching on grants and contracts reflects the university’s contribution to the total costs of a sponsored research project. Cost sharing, therefore, represents the portion of the project costs not paid for by the sponsor. Mandatory cost sharing is required to be reported on the financial reports and to be supported through the accounting records.

General Information

Cost sharing should be limited to those situations where it is mandated by the sponsor. In certain circumstances, the University may determine that a contribution is necessary to ensure the success of a competitive award or competition. All cost sharing dollars require written approval from the source of the commitment.

The PI or department should refrain from making commitments voluntarily, as any promised cost share becomes part of the project cost, even if only mentioned in the narrative and not in the budget. Once awarded, the commitment will have to be tracked in the University’s accounting system and is subject to audit. Failure to comply with the cost-sharing commitment may result in a loss of funding.

Types of Cost Sharing

Typical examples of cost sharing include the percentage of personnel effort to be expended on the project; associated employee benefits; Graduate Research Assistant Tuition and un-recovered indirect costs. Costs incurred prior to the award are not allowable matches. Program income earned under an award may not count as cost sharing unless authorized by the sponsor.

Cash contributions are sources of funds from either internal or external sources.  University cost sharing is considered cash, as it can be accounted for from the University’s records. In-Kind contributions are non-cash contributions typically provided from outside sources such as donations of equipment, sub-contractors of time or facilities, or volunteer services.

Required Approval

Identification of the source of cost sharing is to be made at the time the proposal is submitted. Cost sharing/match accounts are to be set up for each grant as required and used to charge the cost sharing expense. These accounts should be established at the time the award is received and set up in the University’s KFS system.

For internal commitments, the “Cost Share Commitments” section on the Internal Proposal Review form should be completed and signed by the appropriate Unit/Department Head or Dean.

For external (“third party”) cost share, a letter of commitment signed by the contributing party’s authorized official is required.

Criteria for Cost Sharing Commitments

The Uniform Guidance  states that contributions, including cash and third party in-kind, are acceptable as cost-sharing contributions.

The cost sharing/match must meet a number of criteria to be accepted. The contribution must be:

• Verifiable from the recipient’s records. You will be asked to specify an account in the University’s accounting system (KFS);
• Not included as a contribution for any other project;
• Necessary and reasonable to accomplish the project’s objectives;
• Allowable under the Cost Principles;
• Not paid by the Federal Government under another award, except where authorized by Federal statute to be used as cost sharing or matching; and
• Provided for in the approved budget.

A periodic review of the financial statements will ensure that cost sharing commitments are being met and that unrestricted funds to cover the cost share commitment have been transferred in a timely manner to the cost sharing/match accounts. Transfers from unrestricted accounts to the cost sharing accounts should be made in the fiscal year in which the costs are to be incurred.

Fringe Benefits

• The University’s fringe benefit rates are negotiated with its cognizant agency (DHHS) and are part of UConn’s Colleges and Universities Rate Agreement.
• Fringe benefits will be charged at the applicable rate at the time the cost is incurred.
• Sponsored Program Fringe Benefit Rates are to be used when developing all sponsor and cost-share budgets (mandatory and voluntary).
• The following language is required in all proposal budget justifications that include fringe benefit costs using rates listed on the rate agreement:
  “The fringe benefit rates used in the proposal budget are based on the rates approved by the Department of Health and Human Services (DHHS, 9/27/2024) through FY25, and proposed for FY26 and beyond.”

Sponsored Program Fringe Benefit Rates and Projections (%)

* Employee rate category includes Faculty, Professional and Classified Staff, and Postdoctoral Associates
**Special Payroll Examples: Summer faculty, other state agency employees, state retirees, summer graduate students

• A 5% annual increase is recommended and should be applied to personnel salary projections for future budget years for all sponsors except NIH.
• A 3% annual increase is recommended and should be applied to personnel salary projections for future budget years for NIH.
• The months of June, July & August should be used for budgeting purposes for the Summer period
• Graduate assistant stipends below reflect annual increases for future budget years for all sponsors for August 2022 through May 2026.

Graduate Assistants

A full time graduate assistant devotes one-half time to studies (approximately 20 hours per week) and one half-time to graduate assistant duties. During the Summer period, graduate assistants are put on special payroll and can work 40 hours per week.  Refer to the Graduate School website for additional information regarding graduate assistants.  If applying for an individual fellowship or training grant from NIH, refer to the NRSA requirements for stipend, tuition, and institutional allowance.

Graduate Assistant Stipends

In accordance with the Graduate Employee Union Contract, the following stipends represent the minimum stipends for graduate assistants.  Estimates are for proposal development only^†

Graduate Assistant Stipend Level Description:

• LEVEL I – Graduate assistants with at least the baccalaureate degree.
• LEVEL II – Experienced graduate assistants in a doctoral program with at least the master’s degree or its equivalent in the field of graduate study. Equivalency consists of 30 graduate level content course credits of appropriate course work beyond the baccalaureate degree completed at the University of Connecticut, together with admission to a doctoral program.
• LEVEL III – For students with experience as graduate assistants who have at least the master’s degree or its equivalent and who have passed the doctoral general examination.

† Please refer to the Payroll website for updated stipend information.

Post Doctoral Fellow Stipends

• Below are the current National Research Service Award (NRSA) Post Doctoral Fellow stipend levels that should be taken into consideration when preparing your proposal budget. These stipend levels must be used when applying to the NRSA for support. Stipend levels can also be found on the NIH website / NOT-OD-25-105 (effective 5/16/25).
• Use of the stipend level which is consistent with the intended postdoctoral years of experience is recommended for use with other support sources, however, in accordance with University policy, the stipend level must at least be equal to the minimum NRSA rate.
• For more information, visit the Graduate School Post Doc Policies.

Student Labor Pay Scale

Student Labor and Work-Study are paid based on an established pay scale determined by the Office of Student Employment. The rate of pay for a position is based on the skills and level of experience required for the position, regardless of whether earnings are paid through the work-study or student labor payrolls. The pay rate is determined by the hiring supervisor and is subject to approval by the student employment staff in the Office of Student Financial Aid Services.

DHHS Salary Cap

Effective January 1, 2025, the DHHS salary limitation for Executive Level II has been increased to $225,700. For additional information, please refer to NIH Notice NOT-OD-25-085. Note this salary cap applies to all DHHS agencies.

We would love to hear from you. Please use the following links to reach the most appropriate staff persons in the Research Integrity & Compliance areas:

• Institutional Review Board (IRB)
• Institutional Animal Care and Use Committee (IACUC)
• Institutional Biosafety Committee (IBC)
• Financial Conflict of Interest (FCOI)
• Export Control
• Stem Cell Research Oversight Committee (SCRO)
• Research IT eRA Help Desk

Reporting Research Concerns

All concerns related to human research, animal research, conflict of interest, research misconduct, research financial accounting, research safety or other research compliance matters should be reported by calling Research Integrity and Compliance Services at 860-679-2230, Office of University Compliance at 860-486-2530, or the specific area.

Concerns can also be reported anonymously through the REPORTLINE by calling a toll-free number at (888) 685-2637 or via the REPORTLINE website. The REPORTLINE is available 24 hours a day, 365 days a year operated by a private (non-UConn) company. You may contact the hotline to report a concern without giving your name. You will be able to re-contact the REPORTLINE to track your report to provide further information at a later date or to obtain general updates about the status of your concern.

The University welcomes and encourages good-faith reporting. As such, individuals who submit a report or participate in a compliance investigation in good faith are provided protection from retaliation per the University’s Non-Retaliation Policy.

Additional information on reporting concerns can be found at the Office of University Compliance website.

Award Management (Post-Award)

Effort Reporting

Subawards

Incoming Contract Contact by Assigned Academic Unit

Email and Phone: preaward@uconn.edu / 860.486.3622

• Do you have a proposal-specific issue? Please contact your SPS assigned proposal reviewer (see below for portfolio assignments) for assistance via email or Teams call, since they will be most familiar with your proposal.
• Not sure who your assigned proposal reviewer is? For this or non-urgent matters, please email preaward@uconn.edu.
• For more urgent assistance, such as when you are unsure who is reviewing or you have been unable to reach your reviewer,
  please email spshelp@uconn.edu, or call 860.486.1023. Both are actively monitored during regular business hours.

Pre-Award Contact by Assigned Academic Unit

Post-Award Contact by Assigned Academic Unit