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GAP - Recent Updates

Updates to GAPs

July 2019

200.140, Cost Sharing on Sponsored Projects

What's New?

  • Section III, Proposal and Exception
    • Includes pathways for mandatory and voluntary committed cost sharing, as determined by Management Centers
    • Includes requirement to seek approval if cost sharing is identified after project budget is loaded into SAP
  • Section IV, Procedure
    • Describes mechanisms for booking and tracking cost sharing commitments, for salary and non-salary costs
  • Section V, Roles and Responsibilities
    • Includes expectations for Grant Managers, Principal Investigators, Departments, Pre-Award Offices, Management Centers, and Office of Sponsored Projects

What's been revised?

  • Section I, Purpose
    • Revised to include reference to Faculty Handbook, define cost sharing and describe importance of reducing instances of cost sharing
  • Section II, Definitions
    • Revised definitions for Cost Sharing and Types of Cost Sharing (mandatory committed, voluntary committed, voluntary uncommitted, in-kind resources and matching)

200.170, Effort Reporting

What's New?

  • Section III, Roles and Responsibilities
    • Includes expectations for Exempt Employees, Non-Exempt Employees, Primary Effort Coordinators, Effort Proxies, and Office of Post-Award Administration

What's Been Revised?

  • Section I, Purpose
    • Revised for applicable Uniform Guidance definitions of effort and requirements for internal controls around effort certification
  • Section II, ECRT System (Effort Reporting)
    • Revised to describe expectations and reponsibilities under the UG

200.172, Payroll Access for Effort Management on Sponsored Projects

What's been Revised?

  • Section II, Objective
    • Included reference to UG, 2 CFR 200.430 (h)(2) for the definition of IBS

200.330, Facilities and Administrative Costs on Sponsored Projects

What's New?

  • Section IV, Procedure
    • Includes link to Facilities & Administrative Costs: Reduced and Waived Rates (Compliance Guidance)

200.340, Cost Accounting Standards

What's been revised?

  • Section I, Purpose
    • Revised to reference the applicable sections of the UG
  • Section II, Types of Cost
    • Definitions updated to provide consistency with GAPs governing Direct and Indirect Costs

200.360, Charging Clerical and/or Administrative Expenses to Federally Funded Projects

What's New?

  • Section II, Criteria for Charging Administrative Expenses Directly to a Project
    • Includes procedures for administrative salary costs throughout the life of the project

What's Been Revised?

  • Removed references and descriptions of practices for managing projects under Circulars
  • Section II, Criteria for Charging Administrative Expenses Directly to a Project
    • Includes link to 200.160, Rebudgeting Funds on Sponsored Projects
  • Section III, Internal Approval Process for Rebudgeting
    • Renamed section
  • Section IV, Remediation
    • Describes monitoring, detection and remediation steps and timelines for charges made on a CAS G/L account that was not included in the budget or not accompanied by Rebudgeting/CAS form
  • Section V, Thresholds
    • Delegates responsibility for setting and managing thresholds to the Management Centers

June 2019

200.180, Closeout of Sponsored Projects

What's New?

  • Section II. Definitions.
    • Includes definitions for Closeout Period, Closeout Docs Due Date, Sponsor Due Date, Late Activity, Transfer Off Process, and Reportable Award
  • Section V Federal Regulations: includes references to the Uniform Guidance

What's been revised?

  • Section I Purpose.
  • Section III Submission and Processing of Closeout Documentation (Reportable Projects).
  • Section IV Management of Late Activity

200.310, Compensation of Graduate Students on Sponsored Research Projects

What's been revised?

  • Section II, Governmental Requirements
    • Revised to reference the UG and updated requirements, including provision stating the student must be enrolled in an advanced degree academic program

April 2019

200.280, Monitoring Subrecipients

What's New?

  • Section II, Definitions
    • Includes link to Subrecipient/Contractor Determination Form

January 2019

200.100, Capital Equipment Purchases on Sponsored Projects

200.150, Cost Transfers on Federally Sponsored Projects

What's New?

  • Section II. Definitions
    • Includes defintions for Cost Transfers, Unallowable cost transfers, Untimely cost transfers

What's Been Revised?

  • Section I. Purpose
  • Section III. Timeliness
  • Section IV. Procedure
    • Includes process for Manual Salary Cost Transfer
  • Section V. Extra Guidance for DHHS, NIH Awards

200.160, Rebudgeting Funds on Sponsored Projects

What's New?

  • Section II. Sponsor Approvals
    • Updated requirements for rebudgeting requests and submission pathway
  • Section III. Internal Process
    • Updated process to reflect use of Rebudgeting/CAS Form through Duke@Work portal

What's Been Revised?

  • Section I. Purpose

200.290, Program Income -- Federal Grants and Contracts

What's Been Revised?

  • Section II. Definitions
    • Updated Definition to reflect Uniform Guidance specifications
  • Section III. Use of Program Income
    • Updated Options to reflect Uniform Guidance specifications

200.320, Direct Costing on Sponsored Projects

What’s New?

  • Section II. Definitions:
    • Updated definitions of Allowability, Allocability, Reasonableness, Unallowable Costs and Consistency
  • Section II. Select Cost Items
    • Expanded discussion of: Personnel/Salary/Compensation; Computing; Supplies
  • Additional Resource:
    • Direct Costing Guide
    • A/A/R First Principle Guide

What’s been revised?

  • Section I: Purpose
  • Section IV: Documentation
  • Section V: Review and Audit
    • Revised to reflect need for resolution to direct costing concerns prior to final invoice/report being provided to external sponsor.

August 2018

200.420, Processing Payments to Research Participants

What's New?

  • Section II. Summary of Payment Methods
    • Includes Duke ClinCard option and process
  • Section III. Payment Alternative Descriptions
    • Designates Duke ClinCard as primary preferred option, includes description

July 2018

200.370, Purchasing Services on Sponsored Funds

200.372, Purchasing Goods on Sponsored Funds

200.101, Sole Source Justification for Purchases on Sponsored Funds

March 2018

200.330, Facilities and Administrative Costs on Sponsored Projects

What's New?

  • Section II. Definitions
    • Includes definitions for MTDC, On-/Off-Campus designation, Rate Agreement, Unallowable Costs
  • Section III. F&A Rate Types
    • Includes descriptions for Organized Research, Instruction, and Other Sponsored Activities

What's Been Revised?

  • Section IV. Procedure
  • Section V. F&A Rates for Subrecipients