So, How Is Uniform Guidance Implementation Going?
It’s an important question that we need to ask of ourselves in the Federal grants community. Certainly we have peppered you with information about all of the things Federal agencies, pass-through entities, and recipients need to do related to the Uniform Guidance through this blog. With that in mind, it is probably time to take a step back to make sure you and your organization have taken the necessary steps to fully implement 2 CFR 200.
- Document the changes your organization has made to-date. Knowing that an underpinning of the Uniform Guidance is increased transparency, it will be to your organization’s benefit to document the changes made to comply. This way if an auditor comes knocking, you can demonstrate what changes to a system or internal policy were made, when, and who approved the change if appropriate.
- Check those changes made against your original “2 CFR 200 to-do” list. It is possible that your organization has not made all of the necessary changes yet. This is also an opportunity for you to document when a particular item will be changed. Keep in mind that there could be good reason for holding off on the change (i.e., waiting until your new fiscal year before making audit requirement adjustments). You can also raise any red flags with your team on additional changes to policies and processes need to be made.
- Don’t assume that everyone knows the Uniform Guidance. If you work with Federal grants day in day out, then it’s probably reasonable that you know of 2 CFR 200. But do you and your team really know it? I think it’s reasonable that not everyone needs to log onto to eCFR.gov and read every section of Title 2. However, if you are working with the Uniform Guidance regularly, you do owe it to yourself to take the time to familiarize yourself with the changes and the structure of the rules. You also may need to take the time to ensure that you and your colleagues know and understand the nuances of how Federal agencies may have implemented 2 CFR 200 a bit differently.
We are nearing the point when we can stop referring to the “new” 2 CFR 200. These are the rules we must follow as the Federal grants community. We also need to be aware that the these rules are subject to change over time, and staying up to date.
We are also at the point where we can start identifying case studies, best practices, and lessons learned about Uniform Guidance implementation and impacts. Please continue to share your stories and examples in our classes and in the comment section below.