OMB Uniform Guidance

Page created: 2/27/14
Last updated: 7/12/2018

The Office of Management and Budget “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Final Rule” was made effective December 26th, 2014. (2 CFR Chapter I, Chapter II, Part 200, et al.).  Per the OMB, “The Guidance was drawn from OMB Circulars A–21, A–87, A–110, and A–122 (which have been placed in past OMB guidances); Circulars A–89, A–102, and A–133; and the guidance in Circular A–50 on Single Audit Act follow-up.”

Read the full Uniform Guidance: 2 CFR 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards).

Internal Controls

Harvard University is committed to providing good stewardship of sponsored funds. The University’s stewardship responsibilities include:

  • managing Federal awards in compliance with Federal statues, regulations, and the terms and conditions of the Federal award
  • managing non-Federal awards in compliance with sponsor guidelines, and the terms and conditions of the non-Federal award.

Internal Controls are the core of good stewardship of sponsored funds and of an effective Sponsored Programs Compliance Program. Harvard University has a culture of compliance over sponsored research that is bolstered by effective university-wide policies, strong communication and collaboration across the research community, and a nationally recognized training and certification program that helps prepare and train research staff. In addition, staff who are based in central administration research offices and in departments utilize reports to monitor compliance with policies, regulations, and sponsor-specific requirements. Due to the University’s vast scale as well as its decentralized environment, we recognize the importance of documenting controls, clarifying roles and responsibilities, and monitoring the effectiveness of controls. Using the Committee on Sponsored Organization (COSO) Internal Controls Framework, a recognized internal control standard, our overall assessment is that key elements of a sound control environment are in place. 

Effective July 1, 2018, the Sponsored Awards Program matrix (HarvardKey login required), which formalizes the internal controls over research administration processes across the University, is now available.

Resources

Agency Implementation

National Institutes of Health (NIH)
National Science Foundation (NSF)

Other Federal Resources

Videos from NCURA

Harvard OMB Uniform Guidance Working Groups Wiki (Internal Only)