UC Comment Letters

This comment letter responds to the Office of Management and Budget (OMB)'s request for information on proposed revisions to 2 CFR, Subtitle A, Chapters I and II (Uniform Guidance). UC endorses COGR’s comments and recommends that OMB reduce administrative burden under 2 CFR by eliminating the DS-2 requirement, raising the subaward MTDC cap from $25,000 to $75,000 with regular reevaluation, and reconsidering the 26% cap on administrative F&A costs. UC also asks OMB to clarify that negotiated indirect cost rates must be accepted unless limited by statute or regulation, specify that § 200.112 concerns procurement-related conflicts rather than research COI, and rewrite subrecipient indirect-cost-rate rules in plain English so pass-through entities and subrecipients have clear, workable options.