2 CFR 200: A Living Document
It has almost been a year since 2 CFR 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) became effective for Federal grants. The implementation process has provided some challenges to the grants community, such as complying with the new performance measurement requirements or understanding the new time and effort provisions.
One key lesson the grants community has learned in the past year has been the need to remain informed of Federal actions affecting grant awards. The grants community should view 2 CFR 200 as a living document that can, and does, evolve.
For example, in the last few months:
- The Office of Management and Budget (OMB) released final rules implementing the Federal Awardee Integrity and Information System (FAPIIS) that altered the requirements found in 2 CFR 200
- The Council of Financial Assistance Reform (COFAR) updated the Frequently Asked Questions (FAQs) document, which extended the procurement grace period
- The micro-purchase threshold was increased from $3,000 to $3,500.
Beginning January 1, 2016, Federal awarding agencies are required to verify an applicant’s qualifications in FAPIIS before making an award. In addition to the new requirements, OMB amended multiple sections in 2 CFR 200 to implement the FAPIIS requirements. As a result of the changes to 2 CFR 200, the grants community needs to ensure that policies are accurately referencing the correct provisions in the Uniform Guidance.
There have also been important changes to procurement policies. In September, the COFAR updated the FAQs to 2 CFR 200. In the FAQs, the COFAR announced that non-Federal entities now have two full fiscal years to implement the new procurement requirements. 2 CFR 200.110 was amended to reflect the change from a one year to a two year grace period.
Another procurement change affects the micro-purchase threshold. On October 1, 2015, the Federal Acquisition Regulation (FAR) increased the micro-purchase threshold from $3,000 to $3,500. 2 CFR 200.67 directly ties the micro-purchase threshold in the Uniform Guidance to the FAR by stating “the micro-purchase threshold is set by the Federal Acquisition Regulation at 48 CFR Subpart 2.1 (Definitions). It is $3,000 except as otherwise discussed in Subpart 2.1 of that regulation, but this threshold is periodically adjusted for inflation.” While the threshold has not yet been amended in 2 CFR 200, the $3,500 threshold is now applicable to procurements under Federal grants. Non-Federal entities should update internal procurement policies to reflect this change.
The grants community needs to remain aware of changes to 2 CFR 200. As we have seen in the last year, 2 CFR 200 is a living document, which requires the grants community to frequently review and update internal policies and ensure compliance. Management Concepts is committed to bringing you the most current information through our training courses, Grants Blog, Twitter feed, and E-Clips newsletter. By working together, we can ensure a smooth transition to the Uniform Guidance.