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Posted by on Mar 24, 2014

OMB: The Supercircular is “‘Same Same’ But Different”

SameSameOn March 19th, officials from the Office of Management and Budget (OMB) presented at the monthly National Grants Management Association’s (NGMA) March training.  The presentation, entitled “Reducing Red-Tape to Improve Outcomes: The Council on Financial Assistance Reform’s (COFAR) New Uniform Guidance 2 CFR 200,” focused on recent actions by the COFAR to enhance grants management. The presentation provided a high-level examination of policy changes contained in the Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements (the “Supercircular”).

Gil Tran, an official with the Office of Federal Financial Management at OMB, attempted to alleviate the audience’s fears of the upcoming implementation of the Supercircular by displaying a t-shirt he purchased during a recent trip to Vietnam. The shirt read “Same Same” on the front and “But Different” on the back. Tran explained that the saying reminded him of the Supercircular by stating that “it is similar to the current guidance, but different.”

 The Supercircular, Tran explained, maintains general principles of grants management while revising existing policies. The policy revisions are designed to:

  • increase accountability for recipient performance;
  • promote the efficient use information technology;
  • provide consistent and transparent treatment of costs;
  • implement standard business processes and data definitions;
  • encourage family-friendly policies;
  • strengthen oversight;  and
  • mitigate the risk of waste, fraud, and abuse to federal funding.

 The presentation also provided information about how the federal government will implement the Supercircular. OMB plans to publish the 2014 Single Audit Compliance Supplement in April. The Compliance Supplement will contain additional information on how auditors should adhere to the new audit requirements found in the Superciruclar.  By June 2014, agencies are expected to submit to OMB draft rules incorporating the Supercircular into agency regulations. Tran stated that it is OMB’s expectations that agencies will adopt the Supercircular by reference by publishing a final rule as soon as possible. On December 26, 2014, the Supercircular will become effective for all new awards and federal agencies and recipient entities will be required to comply the new policies.

 Tran concluded the training by stating that OMB will be publishing technical corrections to the Supercircular in the Federal Register in the coming months. Tran stated that a review of the Supercircular has identified multiple sections that require edits.  Agency officials are encouraged to submit proposed technical corrections to OMB as soon as possible.

 Stay informed of the latest Supercircular developments by following Management Concepts on Twitter at @Mgmt_Concepts.

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