2 C.F.R. 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements For Federal Awards

Posted on Dec 7, 2014 in Featured, Latest

July 2017: Updated FAQs
The Council on Financial Assistance Reform (COFAR) released updated FAQs on the Uniform Guidance.

December 26, 2014: Implementation of the Policy.  28 Federal awarding agencies adopted the Uniform Guidance into their respective chapters of Title 2 of the Code of Federal Regulations.

Agency exceptions or additions to the Uniform Guidance:   In addition to formally adopting the Uniform Guidance, some agency implementing regulations include exceptions or additions to 2 C.F.R. 200. Agency-specific exceptions do not represent new policy. OMB only accepted exceptions where agencies were able to demonstrate that they were authorized by statute or part of long standing policy. Agency additions include further guidance or clarification that some agencies chose to include in their regulations. To see a cross-walk of agency-specific exceptions or additions, click here.

December 19, 2014: the OMB together with Federal awarding agencies published on the Federal Register a joint interim final rule to implement the new guidance that was published by the Office of Management and Budget (OMB) on December 26, 2013, into their respective chapters of Title 2 of the Code of Federal Regulations.  The Uniform Guidance becomes effective on December 26, 2014. In practice, non-Federal entities are not required to implement the final guidance until they receive a Federal award with terms and conditions that incorporate the Uniform Guidance on or after December 26, 2014.

On December 26, 2013: the OMB released the new guidance for managing Federal Grants and Cooperative Agreements.  The OMB Final Rule for Federal Awards (Uniform Administrative Requirements, Cost Principles, and Audit Requirements) streamlines the language from eight existing OMB circulars into one consolidated set of guidance in the Code of Federal regulations, 2 CFR 200. Upon implementation, the final guidance will supersede requirements from OMB Circulars A-21, A-87, A-110, and A-122 (which have been placed in OMB guidance); Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up.

Supporting materials to facilitate review of the new guidance are posted on the OMB website.

Effective/Applicability Date of the Guidance
Per 2 CFR § 200.110:
(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.”

(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.”

COFAR (The Council on Financial Assistance Reform)
The Council on Financial Assistance Reform (COFAR) is an interagency group of Executive Branch officials established in October 2011 by the Office of Management and Budget (OMB) to identify emerging issues, challenges, and opportunities in grants management and policy and provide recommendations to OMB on policies and actions to improve grants administration. The Council is co-chaired by the OMB Controller, a senior policy official from another agency and members consisting of senior policy officials from nine other Federal agencies. Eight of the agencies are those that provide the largest amounts of financial grants assistance: the Departments of Agriculture, Education, Energy, Health and Human Services, Homeland Security, Housing and Urban Development, Labor, and Transportation.

On Monday, January 27th, 2014, the Council on Financial Assistance Reform (COFAR) held a training webcast for more than 5,000 registered viewers, on the major updates to OMB’s recently reformed guidance on Administrative Requirements, Audit Requirements and Cost Principles for Federal Financial Assistance (2 C.F.R. 200).  The taped training sessions and presentation slides are provided below:

COFAR FAQs:

The Council on Financial Assistance Reform (COFAR) released updated FAQs on the Uniform Guidance September 9, 2015.

 State Of Hawaii, OMB Uniform Guidance (2 CFR 200) Training By Victoria Collin – March 9, 2015
Victoria Collin is a Senior Policy Analyst at the White House Office of Management and Budget (OMB).  At OMB, Victoria is responsible for developing and analyzing policies for the management of $600 billion per year in Federal financial assistance, and for developing and institutionalizing a strong governance framework for the financial assistance community.  Most recently, she has been responsible for building the coalition that developed OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.