New OMB Circular Application to Federally Sponsored International Projects

Institutions engaged in federally sponsored projects abroad 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) ("Circular A-81"). 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.

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