The Supercircular is Coming, the Supercircular is Coming!
In less than two weeks, the much discussed planned changes to Federal grants administration become reality. On December 26, 2014, 2 CFR 200 – Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements – will apply to all new Federal awards. The Office of Management and Budget (OMB) and Federal awarding agencies are expected to release implementing regulations and additional guidance on or around the same day. To help you and your entity prepare for this exciting day, we created the Management Concepts Top 10 Important Items to Know about the Uniform Guidance.
- The Uniform Guidance, sometimes referred to as the “Supercircular or Omni Circular,” is found online at the electronic Code of Federal Regulations.
- The administrative requirements and cost principles in the Uniform Guidance will only apply to new awards issued on or after December 26, 2014 – or – to any funding increments made with modified terms and conditions. Grant recipients should always consult the Federal award document when in doubt to which requirements apply to their awards.
- All Federal awarding agencies will need to implement a pre-award risk assessment and comply with the merit review process outlined in 2 CFR 200.
- The recipient’s fiscal year drives when the Uniform Guidance for audits takes effect. The table below shows a few examples of when your auditors will start following the updated rules.
Fiscal Year Dates
Guidance for Audit Requirements
1/1/2014 – 12/31/2014
7/1/2014 – 6/30/2015
10/1/2014 – 9/30/2015
1/1/2015 – 12/31/2015
7/1/2015 – 6/30/2016
10/1/2015 – 9/30/2016
- You should carefully review the changes to procurement procedures, compensation for personnel services, and indirect (F&A) cost rate policies. 2 CFR 200 makes significant changes to each!
- The Uniform Guidance provides a list of specific responsibilities for pass-through entities.
- Non-Federal entities will have a full fiscal year grace period to implement the new procurement policies and practices under 2 CFR 200.
- Non-Federal entities will need to revise internal policies to define “gratuity violations” that could affect Federal awards.
- Non-Federal entities with awards under both 2 CFR 200 and previous guidance may, as of December 26, 2014, implement entity-wide system changes for all awards to comply with the Uniform Guidance.
- 2 CFR 200 requires non-Federal entities take reasonable measures to safeguard personally identifiable information (PII).
It’s certainly an exciting time for the grants community! Management Concepts looks forward to assisting with all your training needs, including delivery of our Federal Grants Update for 2015. Stay tuned for our Supercircular New Year’s Resolutions!