On August 29, 2014 the Council for Financial Assistance Reform (COFAR) released a second set of FAQs (click here for a user-friendly version) in support of 2 CFR 200. Contained in this document are over two hundred questions and comments OMB received from grantors, grantees, and grant management and oversight professionals across the nation. The purpose of these FAQs is to provide OMB interpretation of the Uniform Guidance in the continuing effort to standardize financial assistance management for both federal and non-federal entities. The layout of the FAQs aligns with the Uniform Guidance sections.
OMB intends to incorporate this FAQ document into future Compliance Supplements, starting in 2015. This means auditors will begin using the FAQs as a standard interpretation of 2 CFR 200 when conducting Single Audits (and other financial assistance-related audits and reviews) after December 26, 2014.
The bottom line is that, while the FAQs are not codified, they do carry weight as the standardized interpretation of the Uniform Guidance.
For more on OMB's intended use of the FAQs, see this video snippet of the October 2, 2014 Uniform Guidance moderated event hosted by OMB and COFAR.
To watch the entire event, click here.