Watch an eLearning describing the Federal Regulation Hierarchy Pyramid (approx. 12 minutes):
This pyramid represents the order of precedence of federal regulations for Awards. The order starts from the top of the pyramid – the federal Award itself – and flows down to the Code of Federal Regulations at the base of the pyramid. Because the UW is a state agency, University policies such as Grant Information Memoranda (GIMs) and Administrative Policy Statements (APS) and Washington State public laws (RCWs) also apply.
To determine applicable regulations, review the Award first for guidance and direction. If the Award is silent, move down the pyramid level by level until the information is located.
- The department has obtained an advance budget so expenditures can be incurred prior to the start date of the Award. The Award makes no reference to pre-Award expenditures. The Uniform Guidance (at the base of the pyramid) states that Sponsor approval is required for all purchases no more than 90 days prior to the start date of the Award. The Sponsor-specific terms and conditions state that Sponsor approval is NOT required. Because the Award makes no reference to this issue, the agency regulations would apply, as agency regulations take precedence over the Uniform Guidance.
- The budget period on an Award is nearing completion and the Award will have a balance of unexpended funds remaining. A new budget period is expected to be issued under the same Award. The Uniform Guidance states that prior approval is required to carry forward funds from one budget period to the next. However, the agency regulations waive this requirement. Yet, written into the Award itself is the requirement that prior agency approval must be obtained to carry forward funds. Because the Award terms take precedence over all regulations in the hierarchy, prior approval to carry forward funds to the next budget period is required.
- A PI is working on a project that requires extensive travel between states to conduct surveys. The PI plans to include GPS with their car rentals for research trips. The PI wants to know if this expense is allowed on their federal Award. The Uniform Guidance states that if the Award recipient does not have its own travel reimbursement policies, the federal policies apply. If the recipient has an acceptable policy, the recipient’s policy would apply.