Countdown to the Supercircular: The Latest Information about the Uniform Guidance
On December 26, 2014, the Uniform Guidance will be applicable to all new Federal grants. The Uniform Guidance, sometimes referred to as the “Supercircular” or “Omni Circular,” contains nearly 100 changes to grants administration and audit requirements for Federal awards.
To help prepare non-Federal entities to comply with the Uniform Guidance, the Office of Management and Budget (OMB) and the Council on Financial Assistance Reform (COFAR) recently published a second set of Frequently Asked Questions regarding the Uniform Guidance.
Additional information from OMB and Federal agencies regarding implementation plans and guidance to non-Federal entities, however, has been sparse.
In the spring, OMB announced plans to release a revised version of the Uniform Guidance containing technical edits. OMB has not indicated when it will publish the revised version. Additionally, in the 2014 Compliance Supplement, OMB announced plans to release an update to Part 3 of the Compliance Supplement by August 30, 2014 to reflect new requirements in the Uniform Guidance. OMB has not published the update and has not publicly provided any additional information.
Federal agencies have also been less than forth coming about their implementation plans. Except for the National Science Foundation, no other agency has released their draft implementing regulations. The draft implementation regulations would indicate an agency’s plans to deviate from the Uniform Guidance. While OMB expects most agencies to adopt the Uniform Guidance by reference, agencies can request that OMB approve expectations to specific provisions.
Gil Tran, an official with the Office of Federal Financial Management in OMB, recently spoke at an American Institute of Certified Public Accountants conference. In his presentation, Tran stated that OMB would release a document containing each agency’s final implementing regulations. The document would also indicate any deviations from the Uniform Guidance. OMB plans to publish the document by December 26, 2014, the date the Uniform Guidance becomes effective for new Federal awards.
Non-Federal entities should use the remaining three months to update policies and procedures to ensure compliance with the Uniform Guidance. Be sure to subscribe to this Blog (use the subscribe form to the right) for any additional updates about the Uniform Guidance.
Uniform Guidance Resources