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Posted by on Dec 19, 2014

And the Supercircular is Here

2 CFR 200

26 Dec 2014

The Office of Management and Budget (OMB) published the interim joint rule implementing the Uniform Guidance (2 CFR 200) in the Federal Register today.  This action ensures that the Supercircular takes effect on schedule on December 26. 

OMB did not indicate any surprises in its release – the bulk of the announcement includes agency implementing regulations.  However, Federal managers, pass-through entities, and non-federal entities will need to review the OMB-approved exceptions included today.  These exceptions are often driven by a Department or Agency’s authorizing statutes or other congressional mandated items. A list of all agency exceptions is found here.

A few important items we noted during our initial review:

  • Procurement Grace Period Included (200.110). 2 CFR 200 provides non-profit organizations and institutions of higher education (IHEs) a one-year grace period to implement the new procurement standards. OMB will include additional information in the 2015 Compliance Supplement.
  • DUNS references updated to “Unique Entity Identifier.”  This change signals that OMB moving away from using DUNS in Federal awards – in line with DATA Act implementation efforts.
  • New Suspension and Debarment section added (200.212).  Non-federal entities and contractors must also ensure they do not use Federal funding to do business with “certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.”

Please note that will be updated once the regulations go into effect on December 26.

We will continue to review the full publication to make sure that our upcoming 2015 Federal Grants Update sessions are up to date.

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