uniform guidance – Resource Library

Happy Belated Fiscal New Year!
Fiscal Year 2021 has ended, and Fiscal Year 2022 is in full swing. Let’s take a look at what’s been happening that impacts the grants community:

Wondering what’s changed? Us too. Specifically, we wondered what had changed between the proposed changes and the final changes to the Uniform Guidance.

Final Changes

Reading OMB’s explanation of the changes to 2 CFR 25, 2 CFR 170, 2 CFR 183, and 2 CFR 200 in the Federal Register (13 August 2020) was helpful, but seeing the actual changes is even more helpful. Thankfully, OMB provided a redlined (aka tracked changes) document showing the final changes at https://www.performance.gov/CAP/grants/#cfr. If you’re only interested in the final changes, this is the document for you, or you can access the changed guidance on the eCFR website at https://www.ecfr.gov/ after it takes effect on 12 November 2020.

Grants policy fanatics (like me) greeted the arrival of the proposed changes to 2 CFR with great excitement. After all, the last time something this big happened in Federal grants was in 2013 when the Uniform Guidance was first issued.

However, if the idea of reading 44 pages of three columns of tiny print (the equivalent of 186 pages at normal print, double-spaced) isn’t your idea of a fun weekend, we’ve distilled the most salient points so you can enjoy your time instead!

While summer is generally the time for taking a long vacation from work, officials at the Office of Management and Budget (OMB) have been busy revising grant policies.

This two-part blog post discusses recent actions that you, a faithful member of the Federal grants community, need to be aware of immediately… or as soon as you get back from the beach, of course.

So, without further ado…

The grants community is under increasing scrutiny and pressure to protect Federal funds from waste, fraud, and abuse. 2 CFR 200 (Uniform Guidance) establishes protections at each part of the grants lifecycle to protect Federal funds from risk. The Uniform Guidance also defines the responsibilities for Federal awarding agencies, pass-through entities, grant recipients, and auditors to guarantee grant funding is used for its intended purposes.

Wouldn’t it be wonderful if all of the billions in Federal Financial Assistance were spent without any violations, overpayments, or nefarious actions? While the Uniform Guidance provides a framework with checks and balances, it’s an impossible task.

Why? We’re human.

One of the most important, and often misunderstood, change under 2 CFR 200 the Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) is the new reporting requirements for employee compensation, found at 2 CFR 200.430.

Federal and non-Federal entities (NFEs) should be well into the process of finalizing internal policies that conform to the new requirements under 2 CFR 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance allows NFEs to adopt entity-wide changes to internal policies and systems for all awards, both existing and new, without penalty. Therefore, a NFE may apply the new requirements found in 2 CFR 200 to all awards.

Tag: uniform guidance