Organizations that perform federal grants and cooperative agreements outside the United States will find new and revised obligations in the Office of Management and Budget (OMB) final guidance titled ‘‘Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards,’’ 72 Fed. Reg. 78,590 (Dec. 26, 2013). This new regulation, often referred to as the ‘‘Super Circular,’’ is a significant development for legal and compliance professionals involved in the day-to-day administration of international federal projects such as research collaborations, public health services, technical assistance, capacity building, and teaching initiatives.
The article “New OMB Circular Application to Federally Sponsored International Projects” prepared by Bill Ferreira and Marta Thompson and published in BNA’s Medical Research Law & Policy Report addresses the operation and administration abroad of grants and cooperative agreements, including new rules on foreign taxes, exchange rates, individuals working overseas, and subawards to foreign entities.
The new regulations take effect in December 2014.