April 6, 1994
Subject: Revised OMB Circular No. A-110
The purpose of this Memo is to send along both a clean copy of the revised OMB Circular A-110 [see Enclosure 1 ] and a copy annotated by the Council on Governmental Relations (COGR), comparing the revisions with the previous circular [see Enclosure 2]. A-110, which contains Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals and Other Nonprofit Organizations, is the model that grant-making Federal agencies will use in their assistance rules in the Code of Federal Regulations (CFR). Thus it does not itself contain grant requirements binding on the University (which is why this Memo is distributed as guidance rather than as an operating requirement). We must await publication of agency A-110 implementations in the CFR in order to assess the potential impact of these revisions. Agency A-110 implementations will continue to be issued via the A-110 Binder Series (see Section 19-212 of the Contract and Grant Manual).
If grant-making agencies were to adopt A-110 verbatim, and assuming that the major agencies will continue to make awards under the Federal Demonstration Project, we would expect the revised A-110 to have minimal impact. Potentially affected areas are:
Definition of equipment: could be set by the recipient institution to any level up to $5,000 [see .2.(I)]. [NOTE: OMB Circular A-21 defines equipment in terms of a $500 threshold; this conflict needs to be resolved before the University can take any action to increase its equipment capitalization level.]
Procedures to minimize the time elapsing between the transfer of funds from the U.S. Treasury and the disbursement by the University: would have to be written [see .21 .(b)(5)].
Remittances of interest on Federal advances: would be consolidated and amounts over $250, annually, would go to DHHS [see .22.(1)].
Equipment screening procedures: are not required [see .44.(a)(1)]. [NOTE: The University is considering eliminating formal equipment screening.]
Form SF-272, Report of Federal Cash Transactions: would be submitted within fifteen calendar (not working) days following the end of each quarter [see .52.(a)(2)(iv)].
Refer: Bill Sellers 510-987-9847
Subject Index: 02, 06, 15, 16
Organization Index: F-005, U-115
David F. Mears
Research Administration Office