The US Office of Management and Budget (OMB) outlines Uniform Administrative Requirements, Cost Principles, and Audit Requirements, also known as the “Uniform Guidance” (UG). The guidance provides a government-wide framework for grants management. The Uniform Guidance is mandatory for awards to states, local governments, institutions of higher education and nonprofit organizations who have received funding from the federal government.
Effective December 26, 2014 “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” was published and combined OMB Circulars A-110, A-21, and A-133. The Office of Management and Budget (OMG) issued updates to the Uniform Guidance 2 CFR § 200 effective August 13, 2020 and November 12, 2020. The revisions apply to awards issued after November 12, 2020. Previous awards are subject to existing Uniform Guidance provisions. More information will be communicated as guidance becomes available from sponsoring agencies and national organizations.
Summary of Uniform Guidance Changes
- Definitions for “budget period” and “period of performance” were created and are used throughout the UG update.
- SAM registration numbers will be replaced with the new Unique Entity Identifier (UEI) – deadline April 2022. Current SAM registrants will automatically receive UEI.
- Reporting threshold of subawards increased from $25,000 to $30,000.
- CFDA have been replaced with the terms “assistance listing number” and “assistance listing program title”.
- Prohibits Federal funds from being used to contract with or procure goods and services from certain foreign entities due to national security concerns – effective August 13, 2020.
- Publication costs may be charged during award close out (after the end of the formal period of performance).
- Pre-award costs must be charged to the initial budget period of the award, unless otherwise specified by the Federal awarding agency.
- Final Financial and Performance Reports due date extended from 90 days to 120 days. Liquidation of all financial obligations extended to 120 days as well. Subaward reports remain due at 90 days.
- Termination “for cause” has been removed from UG. Termination can occur for cause or if an award no longer effectuates the program goals or agency priorities.
- Performance measurement must be provided to show achievement of the program goals and objectives, share lessons learned, improve program outcomes and foster adoption of promising practices.
- Any entity, whether or not they have ever had a federally negotiated F&A rate, may use the 10% deminimus cost rate without the need to provide documentation.
If you have any questions, or need further assistance, please feel free to contact your Office of Sponsored Programs (OSP) Administrator.