Proposed Changes to Uniform Guidance

by | Mar 9, 2020 | Federal Procedures

What is Uniform Guidance?

Uniform Guidance (2 CFR 200) is the culmination of extensive collaboration between the Office of Management and Budget and federal awarding agencies to improve the transparency, oversight and performance of federal awards to non-federal entities.

When OMB released the final draft of Uniform Guidance (2 CFR 200) in December 2014, it drastically streamlined how federal financial assistance instruments (grants & cooperative agreements) were managed. Grantees no longer had to review several OMB Circulars. They were now able to check one source to verify administrative guidelines. However, as federal grants managers know, checking agency regulations, program-specific guidance and the terms of the award agreement completes the compliance picture.

Prior to Uniform Guidance, federal assistance award recipients of all stripes seeking to remain compliant with OMB guidelines referred to either OMB Circular A-122 (Cost Principles for Nonprofits), OMB Circular 21 (Cost Principles for Educational Institutions), OMB Circular A-110 (Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals and other Nonprofits), and/or any of the other five applicable circulars. In all, eight OMB Circulars were integrated, streamlined and repackaged into the singular Uniform Guidance after public comments were sought in response to proposed guidance.

In addition to streamlining eight circulars, a number of federal agencies either adopted Uniform Guidance in its entirety or supplemented it with agency-specific variations (e.g. NASA’s 2 CFR 1800 or HHS 45 CFR 75).

In July 2017, OMB released a FAQ document addressing a number of topics including many on indirect costs, sub awards vs. contracts, methods of procurement, and even the ever popular “should vs. must” language in federal guidelines.

New Changes and Public Comment Period

As outlined in the final rule, Uniform Guidance should be reviewed every five years. Proposed revisions are currently open for public comment through March 23, 2020.

The proposed revisions are meant to be “limited in scope” and intended to reduce recipient burden, provide guidance on new statutory requirements, and improve how federal financial assistance is managed.

Recognizing that grant managers “report spending a disproportionate amount of time using antiquated processes to monitor compliance,” four strategies have been identified to maximize the value of grant funding. The four strategies are: Standardize the Grants Management Business Process and Data, Build Shared IT Infrastructure, Manage Risk, and Achieve Program Goals and Objectives.

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