NACUBO Comments on Potential Changes to OMB Circulars
May 4, 2012
On April 30, NACUBO submitted comments to the Office of Management and Budget (OMB) on proposed reforms to policies and circulars often used by colleges and universities. The comments raised concerns about implementation of a flat indirect cost rate, an increase in the threshold for triggering a single audit, the consolidation of cost principles into a single document, and more. NACUBO also expressed its support for extensive comments submitted by several associations representing research universities and the American Institute of Certified Public Accountants.
On February 28, OMB published an Advance Notice of Proposed Guidance in the Federal Register that announced its intention to reform several policies affecting grants and cooperative agreements, including the cost principles. The ANPG laid out a number of suggestions, many from the federal and nonfederal financial assistance community, for reforming the OMB Circulars. While several proposed reforms could benefit colleges and universities, many of the suggested changes could seriously affect NACUBO members of all types.
After reviewing comments submitted on the ANPG, OMB will publish the proposed amendments for comment. A final notice, outlining the changes and effective dates, will likely be published by the end of the year.
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