2 CFR 200
“Uniform Federal Grant Guidance”
Michael Miller, Auditor
Office of External Audits
May 2014
Objectives and Background
Objectives
“The goal of this reform is to deliver on the President’s directives to (1)
streamline our guidance for Federal awards to ease administrative
burden and (2) strengthen oversight over Federal funds to reduce risks of
waste, fraud, and abuse. Streamlining existing OMB guidance will
increase the efficiency and effectiveness of Federal awards to ensure
best use of the more than $500 billion expended annually….”
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Background
The Development of the Reform
“This proposal reflects input from more than two years of work by the
Federal and non-Federal financial assistance community led by the
COFAR in response to the following two Presidential Directives:”
“1. February 28, 2011, Presidential Memorandum on Administrative
Flexibility, Lower Costs, and Better Results for State, Local, and Tribal
Governments …”
“2. Executive Order 13520 on Reducing Improper Payments …”
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COFAR
Council on Financial Assistance Reform
About the COFAR
“The COFAR, established by OMB Memorandum M-12-01, is comprised
of an interagency group of Executive Branch officials to coordinate
financial assistance. Council activities include providing
recommendations to the Office of Management and Budget (OMB) on
policies and actions necessary to effectively deliver, oversee, and report
on grants and cooperative agreements, as well as sharing with executive
departments and agencies (agencies) best practices and innovative
ideas for transforming the delivery of this assistance. In addition, the
Council will engage relevant stakeholders across Government on key
issues to foster more efficient and effective Federal management by
coordinating the development and implementation of standardized
business processes, data standards, metrics, and information
technology.”
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Agency Members
“The membership of the Council on Financial Assistance Reform consists
of the: Controller of the Office of Management and Budget and senior
policy officials from eight Federal agencies that provide the largest
amounts of financial grants assistance and one additional agency that
serves a two-year term to represent the perspective of other agencies
that administer grants and cooperative agreements:”
•
•
•
•
Department of Agriculture
Department of Education
Department of Energy
Department of Health and Human
Services
• Department of Homeland Security
• Department of Housing and Urban
Development
• Department of Labor
• Department of Transportation
Two-year Term Agency
• National Science Foundation FY12-14
• Department of State FY 14-16
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2 CFR 200 – What is it?
TITLE 2 of the CODE OF FEDERAL REGULATIONS
PART 200—UNIFORM ADMINISTRATIVE REQUIREMENTS, COST
PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS
2 CFR 200 – Are these new regulations?
As stated by OMB:
“To deliver on the promise of a 21st-Century government that is more
efficient, effective and transparent, the Office of Management and Budget
is streamlining the Federal government’s guidance on Administrative
Requirements, Cost Principles, and Audit Requirements for Federal
awards. These modifications are a key component of a larger Federal
effort to more effectively focus Federal resources on improving
performance and outcomes while ensuring the financial integrity of
taxpayer dollars in partnership with non-Federal stakeholders. This
guidance provides a governmentwide framework for grants management
which will be complemented by additional efforts to strengthen program
outcomes through innovative and effective use of grantmaking models,
performance metrics, and evaluation. This reform of OMB guidance will
reduce administrative burden for non-Federal entities receiving Federal
awards while reducing the risk of waste, fraud and abuse.”
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2 CFR 200 – Are these new regulations?
Primarily existing regulations – “This reform streamlines the language
from eight existing OMB circulars into one consolidated set of guidance in
the code of Federal regulations. This consolidation is aimed at eliminating
duplicative or almost duplicative language in order to clarify where policy
is substantively different across types of entities, and where it is not. As a
result, the guidance includes sections and parts of sections which are
clearly delineated by the type of non-Federal entity to which they apply.”
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2 CFR 200 – Are these new regulations?
“This final guidance does not broaden the scope of applicability from
existing government-wide requirements, affecting Federal awards to nonFederal entities including state and local governments, Indian tribes,
institutions of higher education, and nonprofit organizations. Parts of it
may also apply to for-profit entities in limited circumstances and to foreign
entities as described in this guidance and the Federal Acquisition
Regulation. This guidance does not change or modify any existing statute
or guidance otherwise based on any existing statute. This guidance does
not supersede any existing or future authority under law or by executive
order or the Federal Acquisition Regulation.”
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2 CFR 200 – Are these new regulations?
§200.104 Supersession.
As described in §200.110 Effective/applicability date, this Part
supersedes the following OMB guidance documents and regulations
under Title 2 of the Code of Federal Regulations:
(a) A-21, “Cost Principles for Educational Institutions” (2 CFR part
220);
(b) A-87, “Cost Principles for State, Local and Indian Tribal
Governments” (2 CFR part 225) and also Federal Register notice 51
FR 552 (January 6, 1986);
(c) A-89, “Federal Domestic Assistance Program Information”;
(d) A-102, “Grant Awards and Cooperative Agreements with State and
Local Governments”;
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2 CFR 200 – Are these new regulations?
§200.104 Supersession. - continued
(e) A-110, “Uniform Administrative Requirements for Awards and Other
Agreements with Institutions of Higher Education, Hospitals, and Other
Nonprofit Organizations” (codified at 2 CFR 215);
(f) A-122, “Cost Principles for Non-Profit Organizations” (2 CFR part
230);
(g) A-133, “Audits of States, Local Governments and Non-Profit
Organizations,”; and
(h) Those sections of A-50 related to audits performed under Subpart
F—Audit Requirements of this part.
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2 CFR 200 - Contents
Subpart A
Acronyms and Definitions
§§ 200.0 > 200.99
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2 CFR 200 - Contents
Subpart B
General Provisions
§§ 200.100 > 200.113
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2 CFR 200 - Contents
Subpart C
Pre-Federal Award Requirements and
Contents of Federal Awards
§§ 200.200 > 200.211
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2 CFR 200 - Contents
Subpart D
Post Federal Award Requirements
§§ 200.300 > 200.345
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Standards for Financial and Program Management
Property Standards
Procurement Standards
Performance and Financial Monitoring and Reporting
Subrecipient Monitoring and Management
Record Retention and Access
Remedies for Noncompliance
Closeout
Post-Closeout Adjustments and Continuing Responsibilities
Collection of Amounts Due
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2 CFR 200 - Contents
Subpart E
Cost Principles
§§ 200.400 > 200.475
1.
2.
3.
4.
5.
6.
General Provisions
Basic Considerations
Direct and Indirect (F&A) Costs
Special Considerations for States, Local Governments and Indian
Tribes
Special Considerations for Institutions of Higher Education
General Provisions for Selected Items of Cost
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2 CFR 200 - Contents
Subpart F
Audit Requirements
§§ 200.500 > 200.521
1.
2.
3.
4.
5.
6.
General
Audits
Auditees
Federal Agencies
Auditors
Management Decisions
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2 CFR 200 - Appendices
Appendix I
Full Text of Notice of Funding
Opportunity
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2 CFR 200 - Appendices
Appendix II
Contract Provisions for Non-Federal
Entity Contracts Under Federal Awards
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2 CFR 200 - Appendices
Appendix III
Indirect (F&A) Costs Identification and
Assignment, and Rate Determination for
Institutions of Higher Education (IHEs)
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2 CFR 200 - Appendices
Appendix IV
Indirect (F&A) Costs Identification and
Assignment, and Rate Determination for
Nonprofit Organizations
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2 CFR 200 - Appendices
Appendix V
State/Local Government and Indian
Tribe-Wide Central Service Cost
Allocation Plans
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2 CFR 200 - Appendices
Appendix VI
Public Assistance Cost Allocation Plans
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2 CFR 200 - Appendices
Appendix VII
States and Local Government and Indian
Tribe Indirect Cost Proposals
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2 CFR 200 – Appendices - contd
Appendix VIII
Nonprofit Organizations Exempted From
Subpart E—Cost Principles of Part 200
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2 CFR 200 – Appendices - contd
Appendix IX
Hospital Cost Principles
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2 CFR 200 – Appendices - contd
Appendix X
Data Collection Form (Form SF-SAC)
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2 CFR 200 – Appendices - contd
Appendix XI
Compliance Supplement
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2 CFR 200 – Effective Date
§200.110 Effective/applicability date.
(a) The standards set forth in this part which affect administration of
Federal awards issued by Federal agencies become effective once
implemented by Federal agencies or when any future amendment to
this part becomes final. Federal agencies must implement the policies
and procedures applicable to Federal awards by promulgating a
regulation to be effective by December 26, 2014 unless different
provisions are required by statute or approved by OMB.
(b) The standards set forth in Subpart F—Audit Requirements of this
part and any other standards which apply directly to Federal agencies
will be effective December 26, 2013 and will apply to audits of fiscal
years beginning on or after December 26, 2014.
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2 CFR 200 – Effective Date - contd
“Federal agencies must submit draft implementing regulations to OMB no
later than six months from the date of publication of this guidance unless
different provisions are required by statute or approved by OMB.”
“Federal agencies will implement this guidance in unison, which will
provide non- Federal entities with a predictable, transparent, and
governmentwide consistent implementation schedule.”
Again, as stated in subsection (a) publication of these Federal grantor
agency implementing regulations is expected in the Federal Register on
December 26, 2014.
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2 CFR 200 on the Internet
ELECTRONIC CODE OF FEDERAL REGULATIONS
USER NOTICE
The Electronic Code of Federal Regulations (e-CFR) is a currently
updated version of the Code of Federal Regulations (CFR). It is not an
official legal edition of the CFR. The e-CFR is an editorial compilation of
CFR material and Federal Register amendments produced by the
National Archives and Records Administration's Office of the Federal
Register (OFR) and the Government Printing Office. The OFR updates
the material in the e-CFR on a daily basis. The current update status
appears at the top of all e-CFR web pages
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ELECTRONIC CODE OF FEDERAL REGULATIONS
http://www.ecfr.gov/cgi-bin/ECFR?page=browse
Browse:
Select: Title 2 – Grants and Agreements
Select: Go
Select: Hyperlink for 2 CFR 200 which is identified as:
Title 2
Volume 1
Subtitle A
Chapter II
Part 200 – Office of Management and Budget Circulars
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As Published in Federal Register
http://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/2013-30465.pdf
Federal Register Vol. 78 No. 248
Thursday December 26, 2013
Part III
Office of Management and Budget
2 CFR Chapter 1, Chapter II, Part 200, et al.
Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards; Final Rule
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Training & Additional Resources
Uniform Grant Guidance Crosswalks and
Side-by-Sides
1. Uniform Guidance Crosswalk to Predominant Source in Existing Guidance
2. Uniform Guidance Crosswalk from Predominant Source in Existing Guidance
3. Uniform Guidance Definitions Text Comparison
4. Uniform Guidance Administrative Requirements Text Comparison
5. Uniform Guidance Cost Principles Text Comparison
6. Uniform Guidance Audit Requirements Text Comparison
http://www.whitehouse.gov/omb/grants_docs
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Training Webcasts
Uniform Guidance 1-27-14 Training Webcasts
1. COFAR Training Intro
2. COFAR Training Administrative Requirements
3. COFAR Training Cost Principles
4. COFAR Training Audit Requirements
11minutes
1 hour 25 minutes
35 minutes
50 minutes
https://cfo.gov/cofar/
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Frequently Asked Questions
COFAR Releases Frequently Asked Questions
On Wednesday, February 12, 2014, COFAR released the first set of
FAQs in support of 2 C.F.R 200 Uniform Administrative Requirements,
Cost Principles, and Audit Requirements for Federal Awards. Over two
hundred thoughtful questions and comments have been received from
grantors, grantees, and grant management and oversight professionals
throughout country. Additional FAQ releases will parallel Federal agency
submission of implementing regulations. If you have additional questions
or comments please send them to cofar@omb.eop.gov.
Visit
https://cfo.gov/cofar/
https://cfo.gov/wp-content/uploads/2013/01/2-C.F.R.-200-FAQs-2-122014.pdf
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Questions?
Michael Miller, Auditor
Ohio Department of Transportation, Division of Finance
Office of External Audits, Mail Stop # 2140
1980 West Broad Street, 4th Floor
Columbus, Ohio 43223
Ph: 614-466-0588 Fax: 614-887-4772
Michael.Miller@dot.state.oh.us
In accordance with ODOT Central Office requirements, please ensure the Mail Stop number shown above
is used when sending any correspondence to me via US Mail.
http://www.dot.state.oh.us/Divisions/Finance/Auditing/Pages/default.aspx