The Financial Assistance Policy and Oversight (FAPO) Office recently released a Frequently Asked Questions (FAQ) that addressing effective date requirements in the Uniform Guidance (2 CFR 200). Specifically, the FAQ addresses the following:
- Uniform Guidance implementation for awards, subawards, incrementally-funded awards.
- Single Audit (A-133) requirements.
- Indirect Cost Rate development and negotiation.
- Procurement polices and procedures.
- Disclosure Statements (DS-2) of Institutions of Higher Education (IHEs).
You can view the FAQ here.
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.
The Office of Management and Budget (OMB) has provided several crosswalk documents comparing the existing grant management regulations (Uniform Administrative Requirements, Cost Principles, A-133, etc.) to the new Uniform Guidance. Each crosswalk addresses specific comparisons between the current regulations and 2 CFR 200.
- Changes, clarifications, and updates between existing regulations and the Uniform Guidance. (Link)
- Cost Principles and the Uniform Guidance. (Link)
- A-133 and the Uniform Guidance. (Link)
- Definitions between existing regulations and the Uniform Guidance. (Link)
- Uniform Administrative Requirements (A-110, A-102) and the Uniform Guidance. (Link)
Also, there is a comparison chart outlining where the language originated for each section of the Uniform Guidance (e.g. from A-102, A-110, A-87, A-133, etc). (Link)
You can find all of these crosswalk documents on the OMB section of the White House website (http://www.whitehouse.gov/omb/grants_docs/).
(Broadcasted live on Thursday October 2nd, 1:00-3:00PM)
The event includes moderated sessions with relevant stakeholders covering various aspects of 2 C.F.R 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance for Federal Awards), including internal control; blended funding; procurement; pass-through entities and indirect cost rates; and Indian tribe exceptions.
Session 1: Internal Controls from Uniform Guidance COFAR Conversation
Session 2: Procurement Standards from Uniform Guidance COFAR Conversation
Session 3: Single Audit Reporting from Uniform Guidance COFAR Conversation
Session 4: Administrative Flexibilities and Performance from Uniform Guidance COFAR Conversation
Session 5: Indirect Cost Rates for Subrecipients: Uniform Guidance COFAR Conversation