Grant Guidance Changes

2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards The “Supercircular”

2 CFR 200 Issuance Final Rule published by the US Office of Management & Budget (OMB) in the Federal Register in Vol. 78, No. 248 on December 26, 2013. Supersedes the requirements of OMB Circulars A-21, A-87, A-110, and A-122; Circulars A-89, A-102 and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up.

2 CFR 200 Applicability Uniform implementation effective December 26, 2014; applicable to new awards and to incremental funding awarded on or after December 26, 2014. One exception – Subpart F (Audit Requirements) is effective the first fiscal year beginning after December 26, 2014. Existing awards will continue to be governed by the terms and conditions of the Federal award. However, non-federal entities implementing entity-wide system changes to comply with the uniform guidance after December 26, 2014 may also apply the changes to existing Federal awards.

2 CFR 200 Purpose Establish uniform administrative requirements, cost principles, and audit requirements for federal awards to non-Federal entities.

2 CFR 200 Benefits Establishes a government-wide framework for grants management. Reduces the administrative burden for non-Federal entities by: Eliminating duplicative and conflicting guidance Providing consistent and transparent treatment of costs Reduces the risk of waste, fraud and abuse by: Focusing on performance over compliance for accountability Limiting allowable costs to make the best use of Federal resources Strengthening oversight Targeting audit requirements Encourages family friendly policies.

2 CFR 200 Framework Divided into seven subparts: Subpart A: Acronyms and Definitions Subpart B: General Provisions Subpart C: Pre-Federal Award Requirements and Contents of Federal Awards Subpart D: Post Federal Award Requirements Subpart E: Cost Principles Subpart F: Audit Requirements

2 CFR 200 Framework Eleven Appendices: I: Full text of Notices II: Contract provisions for Non-federal Entity Contracts Under Federal Awards III: F & A Cost Identification & Assignment, and Rate Determination for Institutions of Higher Education IV: F & A Cost Identification & Assignment, and Rate Determination for Nonprofit Organizations V: State/Local Government and Indian Tribe-wide Central Service Cost Allocation Plans

2 CFR 200 Framework Appendices: VI: Public Assistance Cost Allocation Plans VII: States and Local Government and Indian Tribe Indirect Cost Proposals VIII: Nonprofit Organizations Exempted From Subpart E- Cost Principles IX: Hospital Cost Principles (45 CFR 74, Appendix E) X: Data Collection Form XI: Compliance Supplement

2 CFR 200 Changes Performance Measurement (2 CFR 200.301) The Federal awarding agency must require the non-Federal entity to use OMB-approved government-wide standard forms when providing financial and performance information. The non-Federal entity will be required to relate financial data to performance accomplishments and when applicable, provide cost information to demonstrate cost effect practices.

2 CFR 200 Changes Prior Written Approval (2 CFR 200.407) Provides a one-stop comprehensive list of the situations under which the non-Federal entity should seek prior approval from the Federal awarding agency. Indirect Costs (F&A) (2 CFR 200.414) In addition to the procedures in the appendices, a non-Federal entity (exceptions apply) that has never received a negotiated indirect cost rate may elect to charge a de minimis rate of 10% of Modified Total Direct Costs (exceptions apply).

2 CFR 200 Changes Audit Requirements (2 CFR 200.507) Requires non-federal entities expending $750,000 or more of Federal funds during the non-entity’s fiscal year must have a single or program-specific audit. Program Income (2 CFR 200.307) Redefined (2 CFR 200.80) to include “the use or rental of real or personal property acquired under Federal awards, the sale of commodities or items fabricated under a Federal award, license fees and royalties on patent and copyrights, and principal and interest on loans made with Federal awards.” (new) The Federal awarding agency may negotiate agreements with non-Federal entities regarding the appropriate uses of income earned after the period of performance.

2 CFR 200 Changes Selected Items of Cost (Subpart E) 200.432 Conferences (change) – allowable conference costs paid by the non-Federal entity as a sponsor or host of the conference may include rental of facilities, speakers’ fees, costs of meals and refreshments, local transportation and other items incidental, unless restricted by terms and conditions of the award. (new) The costs of finding (not providing) locally available dependent care resources are allowable.

2 CFR 200 Changes Selected Items of Cost (Subpart E) 200.438 Entertainment Costs (change) – allowable when costs have a program purpose and are authorized either in the approved budget or with prior written approval of the Federal awarding agency. 200.441 Fines, Penalties, Damages and Other Settlements (change) – costs resulting from violations and alleged violations of Federal, State, Local, Tribal and foreign laws are unallowable except when incurred as a result of award compliance.

2 CFR 200 Changes Selected Items of Cost (Subpart E) 200.474 Travel Costs (new) – temporary dependent care costs (meeting specific standards) above and beyond the regular dependent care that directly results from travel to conferences is allowable.

2 CFR 200 Implementation FEMA is currently working with DHS to promulgate implementing regulation; which will need to first be approved by the OMB. Once approved, the DHS CFO Financial Management Policy Manual will be updated. Publication of implementing policy is expected to on or before December 26, 2014. End of presentation.

2 CFR 200 Questions ?

Federal Funding Accountability and Transparency Act (FFATA)