Understanding Subrecipient vs. Contractor Determination

If your organization receives federal grants and enters into agreements with subrecipients or contractors, it is critical that the substance of the relationship with each is fully understood. This is crucial for several reasons but the primary reason is that it is required (see Uniform Guidance – 2 CFR 200.332 – Requirements for pass-through entities).Continue reading “Understanding Subrecipient vs. Contractor Determination”

Uniform Guidance – The Final 2020 Edition

The August 13, 2020 issue of the Federal Register included the final guidance for the revision of 2 CFR 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance). All revisions except amendments to two sections are effective November 12, 2020; two sections became effective the date of publication in theContinue reading “Uniform Guidance – The Final 2020 Edition”

(Updated) – A Summary of OMB M-20-17: Administrative Relief for Recipients of Federal Financial Assistance Impacted by COVID-19

This post was updated on June 23, 2020 to include the extension of expiration dates for two areas of administrative relief as outlined in M-20-26 released on June 18, 2020. On March 19, 2020, the Office of Management and Budget released M-20-17, Administrative Relief to Recipients and Applicants of Federal Financial Assistance Directly Impacted by theContinue reading “(Updated) – A Summary of OMB M-20-17: Administrative Relief for Recipients of Federal Financial Assistance Impacted by COVID-19”

Proposed Changes to Uniform Guidance

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, itContinue reading “Proposed Changes to Uniform Guidance”