1. Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards
Presented by:
Belinda Rinker, JD
Senior policy analyst
Office of Head Start

2. New Fiscal Regulations
OMB Uniform Guidance - Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards
2 CFR 200
Department of Health and Human Services Implementing Regulations
45 CFR Part 75
Office of Head Start

3. The Uniform Guidance
The
Super
Circular
The
Omni
Principles

4. Objectives of the Uniform Guidance
Focusing on performance over compliance for accountability
Limiting allowable costs to make best use of federal resources
Strengthening oversight
Targeting waste, fraud, and abuse
Eliminating duplicative and conflicting guidance
It is important to note that the regulations focus on performance as opposed to compliance. In substance, the Uniform Guidance tells us that funds must be both properly spent and used wisely in a way that accomplishes their intended purpose.
Office of Head Start

5. Who is covered?
Non-Federal Entities (NFE) (recipients and sub recipients) that expend at least $750,000 in federal funds during the fiscal year:
State governments
Local governments
Indian tribes
Institutions of higher education
Nonprofit organizations
Agencies may apply the requirements to for- profit entities.
HHS/ACF/OHS has not done so to date.
It is important to note that the regulations focus on performance as opposed to compliance. In substance, the Uniform Guidance tells us that funds must be both properly spent and used wisely in a way that accomplishes their intended purpose.
Office of Head Start

6. Current regulations provide detailed guidance specific to entity type.
New regulations provide less detail and more grantee options.
Previous regulations had a lot of detailed information about how to comply. Like different speed limits for day, night, trucks, school zones, flashing lights for hazards. New regulations are much less prescriptive and aim toward reasonableness. Will work well for otherwise high functioning grantees, but others may end up in the fiscal ditch.
What is different?

7. Eliminates Duplicative and Conflicting Regulations
2 CFR 200 Replaces
45 CFR Part 75 Replaces
Audit Circulars for:
Awards received
A-102 & A-89
A-87
A-133 & A-50
Subawards to universities
A-110
A-21
Subawards to nonprofits
Cost Principles
2 CFR 215
2 CFR 220
2 CFR 225
2 CFR 230
HHS Grants Administration Requirements
45 CFR Part 74
45 CFR Part 92
This slide shows the many regulations that are superseded by the new Uniform Guidance.
Eliminates Duplicative and Conflicting Regulations

8. Guidance to assist grantees in planning for implementation
Guidance to assist grantees in planning for implementation. Click here to access the IM on ECLKC.
The OHS has provided resources for awardees to assist in implementing the new Uniform Guidance. You can access them on the Early Childhood Knowledge and Learning Center (ECLKC). See Information Memorandum 14-07…
ACF-IM-HS-14-07
Issued December 17, 2014

9. Presenters: Ann Linehan, OHS Terry Ramsey, HHS Belinda Rinker, OHS Jim Belanger, Danya Click here to access Webinar and Q & A on ECLKC.
And the Webinar and Q & A also found on ECLKC.
Originally presented on February 10, 2015

10. Additional Resources
Uniform Administrative Requirements, Cost Principles, and Audit Requirements
2 CFR Part 200
Frequently Asked Questions for New Uniform Guidance at 2 CFR 200 (COFAR/OMB)
Council on Financial Assistance Reform (COFAR) website
Link to the HHS implementing regulations
45 CFR Part 75 (full explanation) and regulations only
American Institute of Certified Public Accountants (AICPA) Government Accounting Quality Center (GACQ) website
A thorough understanding of the reasons for change is critical for thoughtful implementation.
It is important to take the time to fully understand the background and context of the Uniform Guidance, which will help in implementing necessary changes in your program.
Office of Head Start

11. Uniform Guidance on ECLKC
resources
1. Get familiar with the definitions in the Uniform Guidance, which are all grouped in Section 75.2.
Cost allocation is especially important and cost allocation plans and proposals under the Uniform Guidance require certification by the agency.
Indirect costs are broken down by agency types and included in appendices to the Uniform Guidance.
The de minimis rate, available only to agency’s that have never had a negotiated indirect cost rate, is new to the Uniform Guidance.
Procurement language and thresholds have changed, and Part 75 allows a year for transition to full compliance for procurement policies and procedures.
Don’t forget the individual items of cost, several of which have changed in the Uniform Guidance.
Look carefully at the contract provisions required in Appendix II of Part 75.
Office of Head Start

12. Current Fiscal Policies and Procedures
Planning for Change
No Change
Working well for the organization and no efficiency gained or high cost associated with making changes.
May Change
Working for the organization, but change is likely to increase efficiency or effectiveness or both.
Must Change
Is not compliant with the Uniform Guidance and Part 75.
Current Fiscal Policies and Procedures
Consider a three level approach. Initially address any areas of your fiscal policies and procedures that are not compliant with the Uniform Guidance. The consider where you may have greater flexibility in the Uniform Guidance and changes that may make your fiscal operations more efficient and effective. In the third category, don’t rush to change what remains compliant and works well for your organization.
Office of Head Start

13. Look Closely At: Definitions Cost Allocation Indirect Costs
Compensation (personal services & fringe benefits)
Indirect Costs
Negotiated indirect cost rate
De minimis rate of 10%
In the cost allocation plan
Procurement
Less than $3,000 (micro-purchases)
$3,000 - $149,999 (small purchases)
$150,000 or more
Individual items of cost
Contract provisions
1. Get familiar with the definitions in the Uniform Guidance, which are all grouped in Section 75.2.
Cost allocation is especially important and cost allocation plans and proposals under the Uniform Guidance require certification by the agency.
Indirect costs are broken down by agency types and included in appendices to the Uniform Guidance.
The de minimis rate, available only to agency’s that have never had a negotiated indirect cost rate, is new to the Uniform Guidance.
Procurement language and thresholds have changed, and Part 75 allows a year for transition to full compliance for procurement policies and procedures.
Don’t forget the individual items of cost, several of which have changed in the Uniform Guidance.
Look carefully at the contract provisions required in Appendix II of Part 75.
Office of Head Start

14. Critical Questions Are you aware of the new Uniform Guidance?
Have you determined when you must comply with the Uniform Guidance for each award?
Have you compared the Uniform Guidance requirements to your existing fiscal policies and procedures?
Were necessary changes in fiscal policies and procedures made?
Has implementation of changes begun, including training for impacted staff?
Were the revised fiscal policies and procedures approved by the Governing Body and Policy Council?
It is important to note that the regulations focus on performance as opposed to compliance. In substance, the Uniform Guidance tells us that funds must be both properly spent and used wisely in a way that accomplishes their intended purpose.
Office of Head Start

15. Questions and Comments
The OHS has provided resources for awardees to assist in implementing the new Uniform Guidance. You can access them on the Early Childhood Knowledge and Learning Center (ECLKC). See Information Memorandum 14-07…