March 15, 2017

Research Terms and Conditions Implementing the Uniform Guidance

In 2005, standard research terms and conditions (known as “RTCs”) were adopted by many (but not all) federal agencies. RTCs allowed principal investigators to manage their federal grants more efficiently and effectively. For example, research projects subject to the RTCs were allowed to incur 90 day pre-award costs.

When OMB issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) in 2013, the RTCs were suspended until a revised set of RTCs for implementing the Uniform Guidance could be developed.

New RTCs have been written to comply with the requirements set out in the Uniform Guidance, and most (but not all) federal agencies are planning to implement the RTCs at different dates in 2017.

The Final Notice of Research Terms and Conditions (RTC) To Address and Implement the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Issued by the U.S. Office of Management and Budget (OMB) was published in the March 14 Federal Register.

Agencies participating, with implementation dates, are:
Note that the Department of Defense is not included; but will implement award terms in compliance with 2 CFR 200.

While the Uniform Guidance outlines provisions that are specific to research, these terms and conditions:
  • Incorporate the entire Uniform Guidance by reference, clarifying or supplementing select provisions where appropriate and consistent with government-wide research policy.
  • Incorporate the latest version of the Frequently Asked Questions for the Office of Management and Budget's Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards at 2 CFR 200.
  • Apply to an award when included as part of the award or when incorporated in the award by reference. Use of the RTCs is envisioned as a streamlined approach that supports the implementation of the Uniform Guidance by providing clarification, supplementary guidance, and, where appropriate, selected options, while meeting the spirit and intent of a uniform implementation.
In addition to the RTCs, three companion resources will be developed: Appendix A, Prior Approval Matrix; Appendix B, Subaward Requirements Matrix; and Appendix C, National Policy Requirements Matrix.

Resources:
March 21, 2017 update: Includes addition of Appendix A Prior Approval Matrix, Appendix C National Policy Requirements; and DOE, HHS/NIH, and NSF Agency Specific Requirements.
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