Note to Reviewer - FY 2015 CA Uniform Guidance Updates

1/28/2015

Note to Reviewer of 1220-0149

The Bureau of Labor Statistics (BLS) is seeking Office of Management and Budget (OMB) approval for a nonsubstantive change to the fiscal year (FY) 2015 Occupational Safety and Health Statistics (OSHS) cooperative agreement (CA) application package.

On December 26, 2013, OMB published a Final Rule in the Federal Register entitled Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Final Rule, also known as the “Super-circular” or “Omni-circular,” streamlined grants administration by creating uniform regulations for cost principles, administrative requirements, and audit requirements by consolidating eight OMB circulars (A-21, A-50, A-87, A‑89, A-102, A-110, A-122, and A-133) into a single document. Federal agencies were given one year to adopt the new guidance. On December 19, 2014, the Department of Labor (DOL) issued its Final Rule entitled Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, which adopted the OMB Rule with the DOL’s exceptions.

The new Uniform Guidance applies to all Federal awards made on or after December 26, 2014. In addition, the Uniform Guidance applies to modifications for additional funding to existing awards that occur on or after December 26, 2014. In order to implement the new Uniform Guidance, the BLS updated the Administrative Requirements section of the FY 2015 OSHS CA. State agencies who submit modifications to their FY 2015 CAs for additional funding after December 26, 2014, will receive and must agree to comply with the new Administrative Requirements, which will supersede the previous Administrative Requirements. State agencies will be required to complete an addendum to the All OSHS Program work statement agreeing to comply with the revised requirements. If no modifications for additional funding are made to the FY 2015 CA, State agencies may continue to follow the current terms and conditions of the FY 2015 OSHS CA. State agencies also may request a modification to their FY 2015 CA in order to replace the current regulations with the new Uniform Guidance.

The updated Administrative Requirements and addendum to the All OSHS Program work statement are attached.