1. Presented by: Dan Parker/FHWA

2. Streamlines the language from eight OMB circulars to one consolidated set of guidance. The following have been combined in this document:  A-21 Cost Principles for Educational Institutions  A-87 Cost Principles for State, Local and Indian Tribal Governments  A-89 Federal Domestic Assistance Program Information  A-102 Awards and Cooperative Agreements with State and Local Governments  A-110 Uniform Administrative Requirements for Awards and Other Agreements with Institutions of Higher Education, Hospitals and other Non-Profit Organizations  A-122 Cost Principles for Non-Profit Organizations  A-133 Audits of States, Local Governments and Non-Profit Organizations  A-50 Audit Follow-Up, (as related to Single Audits)

3.  Focuses Federal Resources on Improving Performance and Outcomes  Ensures Integrity of Federal Funds with Stakeholders  Effective December 26, 2014  Cancels 49 CFR Parts 18 and 19  Application and Policy Implementation 2 CFR 200- Introduction

4.  New Awards authorized on or after Dec 26, 2014  Project Modifications made on or after Dec 26, 2014  Audit Requirements – apply to audits of non- Federal entity fiscal years beginning on or after Dec 26, 2014

5.  Federal Award versus Contract  Federal Award ◦ Uniform Guidance requirements ◦ Subject to Single Audit Threshold  Contract ◦ Utilized to purchase property or services to carry out Award ◦ FAR requirements ◦ NOT subject to Single Audit Threshold Subpart A §200.0-200.99

6.  Performance Measurement §200.301  Greater Focus on Internal Controls §200.303  Payments §200.305  Period of Performance §200.309  Greater Responsibilities for Sub-recipient Monitoring §200.331  Project Closeout §200.343 thru §200.345 Subpart D §200.300- 200.345

7.  Performance Measurement ◦ Must relate financial data to performance accomplishments ◦ Demonstrate cost effective practices ◦ 23 U.S.C. 150 Federal-aid Highway Program Performance Management Measures ◦ Not applicable to FHWA Awards under Title 23 Chapter 1 ◦ Enhanced and Proactive Oversight Subpart D §200.300- 200.345

8.  Consider them Earlier in the Process  Provide Reasonable Assurance  Exercise Judgment - Appropriate and Cost Effective based on the circumstances  Safeguard Personally Identifiable Information (PII) Subpart D §200.300- 200.345

9.  CMIA Treasury/State Agreements minimize New Restrictions for Payments to States  23 U.S.C. 121 limits payments to costs incurred to date plus federal share of value of stockpiled material  Pass-through entities (State DOT) must: ◦ Allow sub-recipients to submit requests for reimbursement at least monthly ◦ Make payment within 30 calendar days after receipt of the billing Subpart D §200.300- 200.345

10.  Imposes a period when project costs can be incurred ◦ Start Date (Project Effective Authorization Date) through the End Date  Based on States Estimated Project Schedule  FMIS Requirements  Advance Construction Impacts Subpart D §200.300- 200.345

11.  Subawards include required data elements and requirements  Pre-award Risk Assessment  Risk Based Oversight Framework  Monitor the activities of the subrecipient Subpart D §200.300- 200.345

12.  90 days after the agreement end date recipient submits: ◦ All Eligible Incurred Costs ◦ Performance and Financial Reports ◦ Specified Project Records  Project Closure no later than 1 Year later Subpart D §200.300- 200.345

13. Subpart E §200.400- 200.475 Generally Consistent with OMB A-87 or 2 CFR 225 Indirect Costs Negotiated Rates: one-time extension of up to 4 years Use ICAP – If the state or local government receives more than $35 million in Federal funds Use de minimus rate of 10% - If a non-Federal entity receives $35 million or less in total Federal awards (could be applied to sub-recipients such as LPAs) Narrative Cost Allocation Methods - Use of Appendix VII

14.  Generally Consistent with OMB A-133  Applicable to audits of non-Federal entity fiscal years beginning on or after Dec 26, 2014  Increased Threshold for Single Audits ◦ Increased from $500,000 to $750,000  Updated Single Audit Compliance Supplement https://www.whitehouse.gov/omb/circulars/a133_compliance_supplement_2015 Subpart F §200.500- 200.521

15.  §200.90- State  §200.306- Cost Sharing or Matching  Stockpile Material and Toll/Bridge Credits  §200.307- Program Income-  ROW Proceeds  §200.317- Procurements by States  State Policies and Procedures and Specific Methods  Sub-recipients 2 CFR 200- Deviations

16.  Project Agreement End Date  Impact of Period of Performance on AC Projects  Procurement by State and subrecipients  De minimis rate/definition of MTDC  Subrecipient monitoring requirements

17. 2 CFR 200- Resources  2CFR200 URL http://www.ecfr.gov/cgi-bin/text- idx?tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl  Council on Financial Assistance Reform (COFAR) https://cfo.gov/cofar/  FHWA Policy and Guidance Center http://www.fhwa.dot.gov/pgc/  2 CFR 200 Implementation Guidance