Check Your Stakeholders’ 2 CFR 200 Knowledge
This is a bit of a mea culpa. At the end of the summer, I checked in with you on your Uniform Guidance implementation. One thing I asked you to do is, “Don’t assume that everyone knows the Uniform Guidance.” In that post, I took for granted that there is a baseline of knowledge out there. I should have stated, “Don’t assume that everyone knows about the Uniform Guidance.”
If you are reading this blog that means you’ve opted-in to expanding your grants knowledge. You can chat about 2 CFR 200 at dinner parties. You may have watched all of the YouTube videos on the COFAR website. You potentially have even signed up for next week’s Get Ready for FAPIIS webinar.
But have you shared this knowledge with your grant stakeholders? You may have – but it can’t hurt to check again, or try another method.
One way that Federal agencies reach their constituents is through training symposiums. These in-person or virtual events provide fantastic opportunities for grantees to connect with program officers, network with fellow recipients, and receive technical assistance. Last week, the Management Concepts grants team had the opportunity to participate in the 1st Annual Outreach Partners Networking Symposium for USDA’s 2501 program. During the symposium, we had the opportunity to exchange knowledge outside of the classroom on the Uniform Guidance. We wanted to share some of the Q&A from this session in case you or someone you know hasn’t asked yet.
- Why was the Uniform Guidance developed?
In response to Executive Orders, the Council on Financial Assistance Reform (COFAR) was established in October, 2011. COFAR has steered efforts to improve Federal grants and cooperative agreements management and accountability, and their work included development of 2 CFR 200.
- What are some key points from the Uniform Guidance that are important for Federal agencies to take note of?
- The Uniform Guidance requires all Federal agencies to perform risk assessments on all entities receiving Federal awards
- The Uniform Guidance also expands upon previously established requirements for Federal agencies to build upon previous audits prior to commencing any new audits
- The raising of the Single Audit Threshold to $750,000 allows agencies to better target larger amounts of at-risk funding
- What are some key points from the Uniform Guidance that are important for pass-through entities to take note of?
- Pass-through entities are required to evaluate a subrecipient’s risk
- Pass-through entities must accept previously negotiated Indirect Cost rates, negotiate with sub-entities to establish an indirect rate, or accept the sub-entity election to incorporate the new 10% de minimus rate into their award
- All pass-through entities must comply with reporting requirements to report all sub-awards
- What are some important takeaways from the Uniform Guidance for all recipients of Federal awards?
- Conflict of interest provisions have been strengthened; the Uniform Guidance requires non-Federal entities to disclose all relevant conflict of interest or criminal violations and provide appropriate certifications. The Guidance provides Federal awarding agencies with strong non-compliance remedies for violations
- The Single Audit Threshold has been raised from $500,000 to $750,000
- There is a clear distinction in the Uniform Guidance regarding non-Federal entity determination of who is a subrecipient and who is a contractor; the treatment of each under the Uniform Guidance is determined by the substance of the award
- The Uniform Guidance provides for a 10% de minimis indirect cost rate non-Federal entities that have never had a negotiated indirect cost rate, which will reduce administrative burdens and barriers to award acceptance for some non-Federal entities. This new rate does not prohibit the non-Federal entity from negotiating and indirect cost rate in the future
- The Uniform Guidance also clarifies allowable direct charges for administrative and clerical services
Of course, this only scratches the surface of what is in the Uniform Guidance. We all must commit to continuous learning as grants management is a living body of knowledge. And it’s one we must share.
Special thanks to MJ White for her assistance with this post.