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NASA UpdateFederal Demonstration Partnership
September 11-12, 2014
The Grand Hyatt Washington NASA Headquarters1000 H Street Northwest [email protected], DC 20001 [email protected]
Office of Management And Budget
OMB Federal Register Notice
December 26, 2013
2 CFR §200
“Objective . . . to reduce both administrative burden and risk of waste, fraud, and abuse.”
September 11-12, 2014 NASA update for FDP 2
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OMB
• The final guidance consolidates the guidance previously contained in the [OMB circulars] into a streamlined format that aims to improve both the clarity and accessibility.” https://www.federalregister.gov/articles/2013/12/26/2013-30465/uniform-
administrative-requirements-cost-principles-and-audit-requirements-for-federal-awards
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OMB
• 2 CFR §1.105 organization and subtitle content provides in part:
“. . . [B]ecause the OMB guidance is not regulatory (federal agency regulations and subtitle B may give regulatory effect to the OMB guidance, to the extent that the agency regulations require compliance with all or portions of the guidance).”
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NASA Implementationof Guidance
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2 CFR§200.1800
Terms & Conditions
Grant and Cooperative Agreement Manual (GCAM)
Guidebook for Proposers
NASA Implementationof Guidance
14 CFR §1274
This covers cooperative agreements with commercial firms having cost-sharing
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Agency Implementations
• Does the Administrative Procedures Act apply to grants and cooperative agreements?
• What about the terms and conditions?
• What about cooperative agreements with commercial firms having cost sharing?
September 11-12, 2014 NASA update for FDP 7
Volunteer Reviewers
September 11-12, 2014 NASA update for FDP 8
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Volunteer Reviewers
September 11-12, 2014 NASA update for FDP 9
http://sara.nasa.gov/
Advice About Evaluation of Work Effort
September 11-12, 2014 NASA update for FDP 10
• Peer reviewers are asked "Is the time allocated appropriate?”
• Our instructions tell proposers to tell me how much time they are actually working on a project vs. how much time they are asking me to cover with NASA $
• Some peer reviewers told me in confidence that it is very difficult at some institutions to put in both numbers, so they only put in the time for which they need support.
• How do other Agencies deal with this? Can the organizations make this easier? Am I asking wrong?
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Questions?
September 11-12, 2014 NASA update for FDP 11