Policies & Compliance

Other Conduct of Research Issues

11.1 Federal Regulations

Research conducted under sponsored projects is governed by a range of federal regulations that establish standards for financial stewardship, administrative oversight, and compliance. The specific requirements that apply to a project depend on the type of funding mechanism (e.g., grant, cooperative agreement, or contract) and the sponsor's applicable rules.

The Office of Sponsored Projects (OSP) assists investigators and departments in identifying, interpreting, and complying with these governing regulations throughout the project lifecycle.

11.1.1 Office of Management and Budget (OMB) Uniform Guidance

The OMB Uniform Guidance (2 CFR Part 200) provides the government-wide framework governing the administration of federal financial assistance, including grants and cooperative agreements. The Uniform Guidance establishes standards for administrative requirements, cost principles, and audit obligations applicable to institutions of higher education and other non-federal entities.

The Uniform Guidance consolidated and replaced the prior OMB Circulars and is now the primary authority for managing federal awards.

11.1.1.1 Subpart E - Cost Principles

Subpart E establishes the cost principles for determining the allowability of costs charged to federal awards. These principles are designed to ensure that the Federal Government pays its fair share of total project costs, determined in accordance with generally accepted accounting principles, except where costs are restricted or prohibited by statute, regulation, or award terms.

11.1.1.2 Subpart D - Post-Award Requirements

Subpart D sets forth post-award administrative requirements that promote consistency and uniformity across federal agencies. These standards address issues such as financial management, procurement, property management, performance monitoring, and recordkeeping for federal awards administered by institutions of higher education and other non-profit organizations.

11.1.1.3 Subpart F - Audit Requirements

Subpart F establishes audit requirements for non-federal entities receiving federal funds. Federal awards received by the University are subject to the State of Utah's Single Audit process, which evaluates internal controls and tests compliance with applicable federal laws, regulations, and award terms using risk-based sampling methodologies.

11.1.2 Federal Acquisition Regulations

The Federal Acquisition Regulation (FAR) governs the acquisition and services by executive-branch federal agencies primarily through federal contracts, including research and development contracts awarded to universities.

The FAR codifies uniform procurement and contracting policies and is jointly issued and maintained under the authority of the:

Department of Defense (DoD),
General Services Administration (GSA), and
National Aeronautics and Space Administration (NASA).

In addition to FAR requirements, individual federal agencies may issue agency-specific supplements and include additional conditions in solicitations and contracts. Requests for Proposals (RFPs) may also impose requirements beyond the FAR.

Because federal contracts present different compliance obligations than grants or cooperative agreements, investigators are encouraged to engage OSP early during proposal development. OSP serves as the University's primary resource for interpreting applicable federal regulations and advising on compliance issues that arise during proposal preparation and award administration.

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