2 C.F.R. Part 200 Uniform Guidance

The U.S. Office of Management and Budget (OMB) has consolidated eight of its existing circulars into one document. This document, entitled
2 C.F.R. Part 200
, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, is commonly referred to as the “Uniform Guidance.” The Uniform Guidance was published in the Federal Register on December 26, 2013, and took effect for the Texas Behavioral Traffic Safety Program starting with the Fiscal Year 2016 grant cycle.
The Uniform Guidance combines eight previously separate sets of OMB guidance:
  • OMB Circular A-133,
    Audits of States, Local Governments and Non-Profit Organizations
    .
  • 2 C.F.R. Part 220 (formerly OMB Circular A-21),
    Cost Principles for Educational Institutions.
  • 2 C.F.R. Part 225 (formerly OMB Circular A-87),
    Cost Principles for State, Local and Indian Tribal Governments
    .
  • OMB Circular A-102,
    Grants and Cooperative Agreements with State and Local Governments
    .
  • 2 C.F.R. Part 215 (formerly OMB Circular A-110),
    Uniform Administrative Requirements for Awards and Other Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations.
  • 2 C.F.R. Part 230 (formerly OMB Circular A-122),
    Cost Principles for Non-Profit Organizations
    .
  • OMB Circular A-50,
    Audit Follow-up
    .
  • OMB Circular A-89,
    Federal Direct Program Assistance Information
    .
For FY 2016, the USDOT’s implementation of OMB Circular A-110 (The Common Rule), 49 C.F.R. Parts 18 and 19, was replaced by the Uniform Guidance as well.
With the Uniform Guidance, OMB’s goal is to:
  • Streamline guidance for federal awards to ease administrative burden.
  • Strengthen oversight over federal funds to reduce risks of waste, fraud and abuse.
  • Focus grant policies on areas that emphasize the achievement of better grant outcomes at a lower cost.
Some key changes resulting from the Uniform Guidance include:
  • Strengthening non-federal entity internal control.
  • Targeting audit requirements on risk of waste, fraud and abuse.
  • Raising the single audit threshold from $500,000 in federal awards per year to $750,000 in federal awards per year.
  • Allowing non-federal entities to charge a de minimis rate of 10% of modified total direct costs if the entity does not have a federally negotiated indirect cost rate.