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Uniform Administrative Requirements


Background

The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 CFR Part 200 is the first consolidation of grant management requirements in many years. Prior to the Uniform Guidance, Federal grant management requirements governing administrative requirements, cost principles, and audit requirements were found in eight separate OMB Circulars that included the following:

  • Administrative Requirements: OMB Circulars A-89, A-102 (29 CFR part 97), and A-110 (29 CFR Part 95)
  • Cost Principles: OMB Circulars A-21 (2 CFR Parts 215 and 220), A-87 (2 CFR Part 225), and A-122 (2 CFR Part 230)
  • Audit Requirements: OMB Circulars A-50 and A-133 (29 CFR Parts 96 and 99)

The Department of Labor's adoption of the Uniform Guidance is found at 2 CFR 2900 which includes a limited number exceptions approved by OMB to ensure consistency with existing policy and procedures.

Additionally, OMB has since published technical amendments to the Uniform Guidance at 2 CFR 200 in the Federal Register. The technical amendments published on December 19, 2014, are located here; those published on September 10, 2015, are located here, and those published on November 9, 2015, are located here. Additionally, DOL published technical amendments to the DOL exceptions at 2 CFR 2900 on December 30, 2015, and these are published here.

A new Frequently Asked Questions document for OMB's Uniform Guidance at 2 CFR 200, is available on the Chief Financial Officer Council's grants page. This document was developed in partnership with the Council on Financial Assistance Reform as one of its final deliverables. The CFOC will continue to make grants management resources available at cfo.gov/grants.

Implementation of the Uniform Guidance will require recipients and subrecipients to review and update all financial and administrative policies, procedures and systems for compliance with the new regulations. However, some provisions, such as the procurement standards, have a delayed effective date to enable grant recipients and subrecipients enough time to make the necessary changes to their policies and systems. Additional information on the grace period can be found at 2 CFR 200.110.

Click HERE for a printable, interactive Uniform Guidance Quick Reference Sheet.

Awards issued ON or AFTER December 26, 2014 must adhere to the following:

  • Uniform Guidance: 2 CFR 200.
  • OMB's approved exceptions for DOL's adoption of the Uniform Guidance: 2 CFR 2900.

Awards issued PRIOR to December 26, 2014 AND received a additional or incremental funding On or AFTER December 26, 2014:

  • These recipients will receive new terms and conditions for the funding awarded on or after December 26, 2014 and will be subject to the new requirements at 2 CFR 200 and 2 CFR 2900.

Awards issued PRIOR to December 26, 2014 AND no additional funding was issued on or after December 26, 2014:

  • These recipients may continue to follow the terms and conditions as outlined in their award documents, including 29 CFR Parts 95 and 97 and the audit requirements at 2 CFR Part 96 and 99.
  • These recipients may request a formal grant modification to replace the existing regulations with the new Uniform Guidance should they choose to standardize internal procedures as all NEW funding will be subject to the new regulations as outlined above.
  • ETA strongly encourages all grantees to shift now to follow the new Uniform Guidance and immediately update policies, procedures and systems in accordance with the Uniform Guidance.

For an interactive copy of the below information click here.

uniform guidance chart

For further information please see TEGL 15-14.