ED adopts the final regulations found in 2 CFR Part 200 (Uniform Guidance dated December 26, 2014), except for 2 CFR 102(a) and 200.207(a). The ED also makes two changes to EDGAR Part 75 to (1) correct a citation in § 75.135(b) and (2) add § 75.263, which addresses the waiver for approval of pre-award costs, except as modified by specific award terms OMB Uniform Guidance.
Note: The proposal solicitation is issued by IES (Institute of Education Sciences) which is funded by ED; the award is issued by US Department of Education. IES is the independent, non-partisan statistics, research and evaluation arm of ED. Its mission is to provide scientific evidence on which to base education practice and policy and to disseminate information in formats that are useful and accessible to educators, parents, policymakers, researchers and the public. It was created in 2002. There are four research and statistics centers under ED.
Summary of Standard Terms
Period of Performance Extensions
- May incur pre-award costs up to 90 days prior to the award date without prior ED approval
- Initiation of first no cost extension is processed by the Office of Contracts and Grants (OCG) by the Research Administrator (RA). Written notice to ED is sent no later than 10 days prior to expiration and must include a reason and a revised end date that does not exceed 12 months.
- Subsequent extensions require ED approval. PI requests must be submitted to the OCG RA no later than 45 days prior to expiration. The PI request must provide:
- revised end date (cannot exceed past the next 12 month period)
- estimate of award balance, budget justification, discussion of remaining scope of work
- reason an extension is needed
- Change of any key person named in the award requires prior ED approval
- Disengagement of the PI for 3 months requires ED prior approval
- A 25% reduction in effort by the PI requires prior ED approval
Restrictions on Allowable Costs
- Faculty salary in excess of institutional base salary requires prior ED approval
- Postage, sundry office items, cost of memberships, subscriptions or other professional activities require a project specific justification sent to the OCG/RA for approval and retained for audit
- Costs of entertainment, amusement diversion and social activities, and any costs directly associated with such costs (such as meals, lodging, rentals, transportation and gratuities) are not allowable
- No ED funds may be spent on costs for coffee breaks for intramural meetings including laboratories, departments and centers
- A meeting or conference hosted by a UH PI and charged to an ED grant must not be promoted as an U.S. Department of Education conference
- UH/OCG has established certain steps that the PI must follow in order to justify refreshments and or working meals on ED sponsored workshops and conferences. Contact OCG/RA should you need those details
- Scholarships/fellowships are allowable only when the purpose of the project is training
- Training grants are awarded at 8% MTDC indirect rate
The use of unrecovered indirect and indirect costs on cost sharing is an allowable match.
- Funds may be re-budgeted into participant support without prior ED approval as long as funds are not re-budgeted into the ‘participant other’ category
- Funds may not be transferred out of the participant support category without prior ED approval
- Re-budgeting between direct cost categories is allowed without prior ED approval as long as the scope of work is not altered. ED may, at its discretion, restrict the transfer of funds among approved direct cost categories should the cumulative amount of transfers exceed 10% of the latest approved total budget.
- Carry-forward between the years is allowed without prior ED approval
Method of Payment is ED Letter of Credit (LOC) an electronic drawdown system: EDCAPS (Education Central Automated Processing Systems) G5 https://www.g5.gov
- Unbudgeted special purpose equipment with a unit cost of $5,000 or more may require prior written approval. PI must provide to the OCG RA:
- a brief justification with a statement confirming the purchase does not change the scope of work
- cost and description of capital purchase
- If required OCG RA will send written request to ED Grant Administrator
- OCG RA must check PeopleSoft-grants to verify the correct budget nodes are entered and indirect will calculate correctly
- award terms and conditions may override standard terms and conditions
- Unbudgeted special purpose equipment costing less than $5,000 may be purchased without prior ED approval under the following conditions:
- PI must send their OCG RA a justification to approve and retain for audit purposes
- Title to property generally vests to UH
- Use of US Carriers required per the Fly America Act; exceptions may be made for certain airlines and routes under “Open Skies” agreements.
- All travel, domestic, foreign and conference, must be itemized and justified in the approved budget
ED utilizes the additive method, cost sharing method and the deductive method as the process that may be implemented to account for program income. The ED Grant Award Notification (GAN) may expressly disallow a specific method.
- Pre-doctoral Training Program Fellow: ‘The research supported here by the Institute of Education Sciences, U.S. Department of Education through Grant #xxxxxxx to the University of Houston. The opinions expressed are those of the authors and do not represent the views of the Institute or the U.S. Department of Education.
- Certification: Cover Sheet (ED 524B) must be included and signed by OCG
- All meeting or conference materials paid for with grant funds must include appropriate disclaimers
- An example: ‘The contents of this (insert type of publication; e.g., book, report, film) were developed under a grant from the Department of Education. However, these contents do not necessarily represent the policy of the Department of Education, and you should not assume endorsement by the Federal Government.’
- PI must provide the ED Program Officer (PO) access either electronically or by paper form every publication of material based on or developed under the award.
Prior approval required for all unbudgeted subcontracting
- Technical reporting must be completed by PI and should be submitted as follows:
- Most GANs do not announce the annual report due dates. The ED Program Person will contact the PI with the reporting due dates. The due date can be anticipated to become due at least 60 days prior to the anniversary date.
- Final report detailing entire project is due within 90 days after expiration
- Cover Sheet ED 524B is reviewed and signed by OCG. It is returned to the PI for submission
- Annual and final reports are submitted through G5 https://www.g5.gov
- Expenditure information is provided to ED through the on-line drawdown system. It has the capacity to make adjustments which eliminates the need to submit financial reports.
- The Cover Sheet ED 524B provides financial information that is verified and signed by OCG. This is submitted with the annual and final report.