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Posted by on Sep 3, 2014

OMB Releases FAQs for the Uniform Guidance

faqsThe Office of Management and Budget released a second set of frequently asked questions about the Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200). This set of FAQs provides additional information to Federal awarding agencies and non-Federal entities preparing to implement the Uniform Guidance, sometimes referred to as the “Superciruclar.” The Uniform Guidance becomes effective for all new Federal awards on December 26, 2014.

In the newly released FAQs, OMB addresses more than 80 concerns from the grants community regarding the Uniform Guidance. Some of the questions addressed include:

  • When may non-Federal entities begin to submit proposals for indirect cost rates based on the Uniform Guidance?
  • Should applications submitted prior to 12/26/2014 for Federal awards which will be made after 12/26/2014 reflect the Uniform Guidance?
  • How are procurements of micro-purchase and small purchases under the simplified acquisition threshold less burdensome than those above it?
  • What processes do non-Federal entities need to follow to be authorized to change their current systems for documenting payroll charges?
  • Will the Federal government provide a grace period after the effective date for non-Federal entities to comply with the procurement standards in the Uniform Guidance?

Click here to access the FAQs.


  1. Do you know if anything in the uniform guidance (or otherwise) prohibits a federally-funded trial program from hiring a felon for program director or any other position paid with federal financial assistance. I mentioned its a tribal program because it is under the Indian Self-Determination Act (PL 93-638).

    Thank you for your response!

    • Hi Arlene,

      Thank you for your question. While 2 CFR 200 does not address the use of grant funding to hire a felon, specific program regulations may prohibit felon employment. It would be critical for you to review the terms and conditions of your award and discuss the situation with your legal counsel and the Federal awarding agency. It is also important to remember that your entity should follow established hiring procedures.

      -Shane Jernigan

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