Departmental Research Administrators
Training Track
2 CFR PART 215 (FORMERLY OMB CIRCULAR A-110)
UNIFORM ADMINISTRATIVE REQUIREMENTS FOR GRANTS
AND COOPERATIVE AGREEMENTS FOR INSTITUTIONS
OF HIGHER EDUCATION, HOSPITALS, AND OTHER NONPROFIT ORGANIZATIONS
UMBC Office of Sponsored Programs
www.umbc.edu/research/OSP
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2 CFR PART 215 – Course Overview
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Section A – Introduction to 2 CFR Part 215
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Section B – Pre-Award Requirements
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Section C – Post-Award Requirements
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Section D – After-the-Award Requirements
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Section E – Additional Resources
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SECTION A – Introduction to 2 CFR Part 215
Questions to Answer:
 Why did OMB develop Uniform Administrative
Requirements?
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What are the Uniform Administrative Requirements
and to whom do they apply?
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What are some recent developments concerning
the administrative requirements?
Why did OMB develop Uniform Administrative
Requirements?
During the 1960’s the federal government
initiated many new grant programs
 Federal agencies were acting independently in
administering their grant programs and
guidelines
 Standardization, consistency, and efficiency of
federal grant programs was sought
 Intergovernmental Cooperation Act of 1968
 1976 – OMB issues A-110
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What are the Uniform Administrative
Requirements and to whom do they apply?
OMB Circular A-102 – for State and Local
Governments, Indian Tribal Governments
 OMB Circular A-110 (2 CFR Part 215)
 A-102 and A-110 apply to all federal agencies,
federal grant recipients and subaward
organizations
 Federal agencies can only apply more restrictive
requirements after approval from OMB
 Federal agencies can impose sanctions on
recipient organizations that do not comply with the
applicable administrative requirements
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What are some recent developments concerning
the Administrative Requirements?
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Title Change – 2 CFR 215
2 CFR 215 will soon include agency specific variations and
exceptions
Standard Reporting Forms:
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Federal Financial Report
Performance Progress Report
Research Performance Progress Report
Real Property Report
Tangible Personal Property Report
Summary Report of Inventions
Standard Research Terms and Conditions
SECTION B: Pre-Award Requirements
Questions to Answer:
 What is the Federal Grant and Cooperative
Agreement Act?
 What forms should be used for applying for
Federal Assistance?
 What is E.O. 12372?
 What are “special award conditions”?
What is the Federal Grant and Cooperative
Agreement Act?
Passed into law in 1977
 Establishes government-wide criteria for
determining the appropriate legal instrument for
funding extramural activity
 Defines uses for:
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Grants – to accomplish a public purpose
 Cooperative Agreements – for substantial agency
involvement
 Contracts – primary purpose is acquisition of services
for direct benefit of Fed
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What forms should be used when applying for
federal assistance?
215.12.A – “Federal awarding agencies shall
comply with the applicable report clearance
requirements of 5 CFR part 1320, ‘Controlling
Paperwork Burdens on the Public,’ in place of or
as a supplement to the Standard Form 424 (SF424) series”
 215.12.B – “Applicants shall use the SF-424
series or those forms and instructions prescribed
by the Federal Awarding Agency”
 Most grants.gov application packages use the SF424 series
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What is E.O. 12372?
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Executive Order 12372 - “Intergovernmental Review of
Federal Programs”
Issued to foster federalism by relying on State and local
processes for the coordination and review of proposed
Federal financial assistance
Applicants are required to indicate on the SF 424 whether
the program falls under E.O. 12372
SPOC for Maryland:
Linda C. Janey, J.D.
Director, Maryland State Clearinghouse for
Intergovernmental Assistance
Please contact OSP for questions on whether or not a project
falls under E.O. 12372
What are “special award conditions”?
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215.14 – “If an applicant or recipient: has a history of
poor performance, is not financially stable, has a
management system that does not meet the standards
prescribed in this part, has not conformed to the terms
and conditions of a previous award, or is not otherwise
responsible, Federal awarding agencies may impose
additional requirements as needed…”
Federal awarding agencies are required to notify the
applicant in writing as to the nature of any additional
requirements, and these requirements must dissolve
after problematic conditions have been met
Section C: Post-Award Requirements
Questions to Answer:
 What are the Financial and Program Management
Standards?
 What are the Property Standards?
 What are the Procurement Standards?
 What are the Reporting and Record-Keeping
Standards?
 What are the Termination and Enforcement
Standards?
What are the Financial and Program
Management Standards?
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Purpose: 215.20 “Sections 215.21 through
215.28 prescribe standards for financial
management systems, methods for making
payments and rules for: satisfying cost sharing
and matching requirements, accounting for
program income, budget revision approvals,
making audits, determining allowability of cost,
and establishing fund availability.”
What are the Financial and Program
Management Standards? (cont’d)
Financial Management Systems:
 215.21.A – “Federal awarding agencies shall require recipients to
relate financial data to performance data and develop unit cost
information whenever practical”
 215.21.B – Recipients’ financial management system should provide
for the following:
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Accurate disclosures of financial results and records in accordance with
applicable reporting reqs.
Effective control over and accountability of funds, property, and other
assets
Comparison of outlays with budget amounts for each award
Written procedures to minimize time between transfer of funds from US
Treasury
Written procedures for determining reasonableness, allocability, and
allowability of costs, in accordance with Federal Cost Principles
What are the Financial and Program
Management Standards? (cont’d)
215.22 Payment:
 (A) Procedures should minimize time before transfer of funds
from U.S. Treasury
 215.22.E.(1) – When reimbursement method is used, the
Federal awarding agency shall make payment within 30 days
after receipt of the billing
 215.22.H – Agency shall not withhold payment for proper
charges during the award period unless:
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Recipient has failed to comply with project objectives, the terms
and conditions of the award, or Federal Reporting Requirements
The recipient or subrecipient is delinquent in a debt to U.S. as
defined in OMB Circular A-129
What are the Financial and Program
Management Standards? (cont’d)
215.23 Cost Sharing:
 (A) Cost-sharing contributions shall be accepted only when the costs are:
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(1) verifiable from the recipients’ records
(2) not included as contributions for any other federally-assisted project
(3) necessary and reasonable for completion of project
(4) allowable under the applicable Cost Principles
(5) not paid by Fed under another award
(6) provided for in the approved budget
(B) Unrecovered indirect costs may be included as part of cost-sharing or
matching only with prior approval of Agency
 (C),(D), (E), (F),(G), (H) – how to delineate value of various contributions
215.25 Revision of Budget and Program Plans:
 (B) Recipients are required to report deviations from budget and program
plans, and request prior approvals for:
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Changes in scope, objective, or key personnel (and/or effort, >25%), direct to
indirect costs, training allowances, subcontracting, etc.
What are the Financial and Program
Management Standards? (cont’d)
215.27 Allowable Costs –
 Recipient needs to follow applicable cost principles
 UMBC – must follow OMB Circular A-21 (a.k.a. 2 CFR
220) “Cost Principles for Educational Institutions”
215.28 Period of Availability of Funds
 “Where a funding period is specified, a recipient may
charge to the grant only allowable costs resulting from
obligations incurred during the funding period and any
pre-award costs authorized by the Federal awarding
agency”
What are the property standards?
215.30 Purpose of property standards
 To set forth uniform standards governing management and
disposition of property furnished by the Federal Government whose
costs was charged to a project support by a Federal award
215.31 Insurance coverage
 Recipient needs to provide at least equivalent coverage for federal
property as it would its own
215.32 Real Property
 Federal awarding agencies shall prescribe requirements that include
the following:
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Title to property to remain with recipient
Recipient shall obtain written approval for its use on other projects
Disposition instructions
What are the property standards? (cont’d)
215.34 Equipment
 (A) title to equipment shall vest in recipient
 (B) if used by outside orgs., fee must be at least the minimum charged in private
industry
 (C) when use for equipment expires, the equipment is to be used on other federally
sponsored projects, first by other projects supported from same funding agency
 (E) “When acquiring replacement equipment, the recipient may use the equipment
to be replaced as trade-in or sell the equipment and use the proceeds to offset the
costs of the replacement equipment…”
 (F.1) Equipment records should include (among other information):
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Description
Serial number
Source
Acquisition date
Location and condition
Unit acquisition cost
Disposition data
What are the property standards? (cont’d)
215.35 Supplies and other expendable property
 (A) title to supplies vest in recipient, if leftover supplies
exceed $5K and can not be used on other projects (federal
and non-federal), then recipient must reimburse the Fed.
215.36 Intangible Property
 (A) “The recipient may copyright any work that is subject to
copyright and was developed, or for which ownership was
purchased, under an award. The Federal awarding agency
(ies) reserve a royalty-free, nonexclusive and irrevocable right
to reproduce, publish or otherwise use the work for Federal
purposes, and to authorize others to do so.”
 (B), (C), (D), (E) – patent rights, FOIA responsibilities, etc. for
Agency and recipient
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What are the procurement standards?
215.44 Procurement Procedures
 (A) Recipients shall establish written procurement procedures
 (A.3.I-VI) Recipient solicitations for goods and services should include (among
others):
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Clear description of the technical requirements for the material, product or service to be
procured
Requirements for the bidder and evaluation criteria
Preference for “green” products and services
(B) Recipient shall make efforts to utilize small business, minority-owned firms, and
women’s business enterprises whenever possible
(C) Recipient shall determine which procuring instrument to use (fixed-price
contracts, cost-reimbursable contracts, purchase orders) in the best interest of the
program
(D) Procurements should only be made with responsible contractors who possess
the ability to perform, have a good history, and have technical/financial resources
(E) Circumstances when consultation with Federal awarding agency should be
sought regarding the procurement
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What are the procurement standards? (cont’d)
215.45 Cost and Price Analysis – “Some form of cost or price analysis shall be
made and documented in the procurement files in connection with every
procurement action.”
 Price analysis – comparison of price quotations, market price, etc.
 Cost analysis – is the “review and evaluation of each element of cost to
determine reasonableness, allocability, and allowability
215.46 Procurement Records – Procurement records should include:
 (A) Basis for contractor selection
 (B) Justification for lack of competition when competitive bids are not
obtained
 (C) Basis for award cost or price
214.47 Contract Administration – “A system for contract administration shall be
maintained to ensure contractor conformance with the terms, conditions
and specifications of the contract to ensure adequate and timely follow up
of all purchases”
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What are the Reporting and Record-Keeping
Standards?
215.50 – Purpose of Reports and Records
“Sections 215.51 -215.53 set forth the
procedures for monitoring and reporting on the
recipient’s financial and program performance
and the necessary standard reporting forms.
They also set forth record retention
requirements”
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What are the Reporting and Record-Keeping
Standards? (cont’d)
215.51 Monitoring and Reporting Program Performance
 Recipients are responsible for managing and reporting all
activity supported by the award (including subawards)
 (A) “Federal Agency shall prescribe the frequency with which
the performance reports shall be submitted. Except as
provided in 215.51 (F), performance reports shall not be
required more frequently than quarterly, or less frequently
than annually.”
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Annual reports should be due within 90 days after the grant year
Quarterly/semi-annual reports shall be due within 30 days after
reporting period
Final performance reports are due 90 days after termination date
of award
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What are the Reporting and Record-Keeping
Standards? (cont’d)
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215.51 (D) – Performance reports should include the
following:
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A comparison of actual accomplishments with program
objectives for that period
Reasons why established goals were unmet, if necessary
Other information as necessary, including explanations for
cost overruns, etc
215.51 (F) – Recipients shall notify the Awarding Agency
of any developments that significantly impact/impair the
program activities
215.51 (G) – “Federal awarding agencies may make site
visits, as needed.”
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What are the Reporting and Record-Keeping
Standards? (cont’d)
215.52(A) Financial Reporting – “The following forms or such other
forms as may be approved by OMB are authorized for obtaining
financial information from recipients”
 215.52.A.(1) – SF-269 or SF-269A, Financial Status Report (FSR)
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Federal agency shall require recipients to use SF-269 or SF-269A for all
nonconstruction programs
However, agencies have the option of not requiring SF-269/SF-269A, if
the SF-270, Request for Advance or Reimbursement, or SF-272, Report
of Federal Cash Transactions, is used and provides adequate
information
Federal Agency will determine whether the report shall be on a cash or
accrual basis
FSR should not be required more frequently than quarterly or less
frequently than annually
FSR’s should be due within 30 days after reporting period, Final FSR’s
within 90 days of award termination
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What are the Reporting and Record-Keeping
Standards? (cont’d)
215.52.A.(2) – SF-272 Report of Federal Cash
Transactions
 Used when funds are advanced to recipients in
order to monitor cash advancements
 Forecasts of expenditures may be required
 SF-272 are due within 15 days following the
end of each quarter. Recipients receiving more
than $1million/year need to submit report
monthly
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What are the Reporting and Record-Keeping
Standards? (cont’d)
215.53 Retention and access requirements for records
 215.53.B – “Financial records, supporting documents, statistical records, and all
other records pertinent to an award shall be retained for a period of three years from
the date of submission of the final expenditure report”
 Exceptions:
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If any litigation,claim, or audit is in process
Records for real property and equipment need to be retained for three years after final
disposition
If/when records are transferred to Awarding agency, the three year requirement is no longer
applicable
215.53.E “The Federal Awarding Agency, the Inspector General, Comptroller General
of the United States, or any of their duly authorized representatives, have the right of
timely and unrestricted access to any books, documents, papers, or other records of
recipients that are pertinent to the awards, in order to make audits, examinations,
excerpts, transcripts and copies of such documents.”
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Access to personnel also included
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What are the Reporting and Record-Keeping
Standards? (cont’d)
215.53.F – No Federal Agency can impose restrictions on
recipients that limit public access to the records
pertinent to an award
215.53.GG – Indirect cost rate proposals, cost allocation
plans, etc.
 (1) Records submitted as apart of IDC calculation, cost
allocation plans, etc. must be retained for three years
after that submission date
 (2) If records are not submitted as apart of IDC
calculation, cost allocation plans, etc., then records
should be retained for three years after end of the fiscal
year of that proposal
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What are the Termination and Enforcement
Standards?
215.61 Termination
 (A) Awards may be terminated if:
The recipient materially fails to comply with the terms
and conditions of the award
 Both the Federal Agency and Recipient agree to
terminate , and to the termination conditions
 “By the recipient upon sending to the Federal awarding
agency written notification setting forth the reasons for
such termination, the effective date, and, in the case of
partial termination, the portion to be terminated.”
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What are the Termination and Enforcement
Standards? (cont’d)
215.62 – Enforcement
 215.62.A. – Remedies for Noncompliance:
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215.62.B. – Hearings and appeals
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Federal agencies are able to withhold cash payments pending
problem resolution
Disallow costs associated with noncompliance
“Wholly or partly suspend or terminate the current award.”
Withhold further awards for the project/program
Awarding agency shall provide opportunity for recipient to appeal
any disciplinary action taken by Agency
215.62.C. – Costs incurred during a suspension or after
termination of an award are not allowable unless written into
termination/suspension conditions
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Section D: After-the-Award Requirements
Question to Answer:
 What are the standards for closeout
procedures?
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What are the standards for closeout procedures?
215.71 – Closeout Procedures
 215.71(A) – “Recipients shall submit, within 90 calendar days after
the date of completion of the award, all financial, performance, and
other reports as required by the terms and conditions of the award.
The Federal awarding agency may approve extensions when
requested by the recipient.”
 215.71(B) – “Unless the Federal awarding agency authorizes an
extension, a recipient shall liquidate all obligations incurred under
the award not later than 90 calendar days after the funding period or
the date of completion…”
 (C), (D), (E), (F), – Fed shall make prompt payments to recipient,
recipient shall promptly refund unobligated balances (OMB Circular
A-129), if authorized by award terms/conditions Agency shall make
adjustments for Federal Share, real/personal property to be
accounted for
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What are the Termination and Enforcement
Standards? (cont’d)
215.72 Subsequent adjustments and continuing
responsibilities.
 (A) “The closeout of an award does not affect any of the
following.”
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(1) Right of the Federal awarding agency to disallow costs or
recover funds on basis of later audit review
(2) continued obligation of the recipient to return funds due
as a result of corrections, audit, etc.
(3) “Audit Requirements in 215.26”
(4) Property management requirements
(5) Record retention requirements
215.73 Collection of Amounts Due
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Section E: Additional Resources
2 CFR 215 “Uniform Administrative Requirements for Grants and Cooperative Agreements for Institutions
of Higher Education, Hospitals, and other Non-Profit Organizations” (formerly OMB Circular A-110)
available at:
http://www.whitehouse.gov/omb/circulars/a110/a110.html
OMB Circular A-21 “Cost Principles for Educational Institutions” available at:
http://www.whitehouse.gov/omb/circulars/a021/a021.html
Standard Forms for reporting available at:
http://www.whitehouse.gov/omb/grants/grants_forms.html
www.umbc.edu/ospa
www.umbc.edu/procurement
www.umbc.edu/FinancialServices/grantacct.html - Grant and Contract Accounting
www.umbc.edu/otd - UMBC Office of Technology Development
All Federal Agency/Grantor websites
www.grants.gov
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