2 C.F.R. Uniform Guidance: Subpart B

In this blog post, we are going to cover OMB Circular 2 CFR Subpart B. We will discuss the purpose of Subpart B, Applicability, Conflict of Interest, and more. It is essential to understand what's in 2 CFR so that you can research, apply, write, and manage grants effectively. Federal funds require accountability and transparency. Let's get started with Section 200, Subpart B.

Section 200. 1XX Subpart B - General Provisions Includes,

200.100 Purpose.
200.101 Applicability.
200.102 Exceptions.
200.103 Authorities.
200.104 Supersession.
200.105 Effect on other issuances.
200.106 Agency implementation.
200.107 OMB responsibilities.
200.108 Inquiries.
200.109 Review date.
200.110 Effective date.
200.111 English language.
200.112 Conflict of interest.
200.113 Mandatory disclosures.

200.100 Purpose

a. (1) This part establishes uniform administrative requirements, cost principles, and audit requirements for Federal awards to non-Federal entities.

(2) It provides the basis for a systematic and periodic collection and uniform submission by Federal agencies of information on all Federal financial assistance programs to the OMB. Also, established Federal policies related to the delivery of this information to the public, including through the use of electronic media.

b. Administrative requirements Subpart B through D set forth the uniform administrative requirements for grant and cooperative agreements, including the requirements for Federal awarding agency management of Federal award has been made.

c. Cost principles. Subpart E-Cost Principles of this Part establishes principles for determining the allowable costs incurred by non-Federal entities under Federal awards.

d. Single Audit Requirements and Audit Follow-up. Subpart F-Audit Requirements sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of non-Federal entities expending Federal awards. They also provide policies & procedures for Federal awarding agencies and pass-through entities when using the results of these audits.

200.101 Applicability

a. General applicability to Federal agencies. The requirements established in this Part apply to Federal agencies that make Federal awards to non-Federal entities. (Describes the applicability of each subparts to types of Federal awards).

b. (1) New table for applicability by types of award. (Must be read along with the entire applicability section).

The terms & conditions of Federal awards flow down to subawards to subrecipients unless a particular sections of the Part or the terms & conditions of the Federal award specifically indicate otherwise. (Meaning, the Federal awarding agency will determine applicability & state the applicable requirements in the terms & conditions of the Federal award. Therefore, it's the pass-through entity is required to state the terms & conditions of subawards to their subrecipients as well.)

200.104 Supersession

The effective date 12/26/14 supersedes the following OMB guidance documents & regulations under Title 2 of the Code of Federal Regulations:

A-21, Cost Principles for Educational Institutions (2 CFR Part 220)
A-87, Cost Principles for State, Local and Indian Tribal Governments
A-89, Federal Domestic Assistance Program Information
A-102, Grant Awards and Cooperative Agreements with State & Local Governments.
A-110, Uniform Administrative Requirements for Awards and Other Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations.
A-122, Cost Principles for Non-Profit Organizations.
A-133, Audits of State, Local Governments, and Non-Profit Organizations.

200.110 Effective/Applicability Date

(a) Federal agencies must implement the policies & procedures applicable to Federal awards by promulgating a regulation to be effective by December 26, 2014.

(b) The standards set forth in Subpart F-Audit Requirements will be effective December 26, 2013 and will apply to audits of fiscal years beginning on or after December 26, 2014.

200.112 Conflict of Interest (NEW)

The Federal awarding agency must establish conflict of interest policies for Federal awards.
The non-Federal entity must disclose in writing any potential conflict of interest to the Federal awarding agency or pass-through entity.

200.113 Mandatory disclosures (NEW)

The non-Federal entity or applicant of a Federal award must disclose, in a timely manner, in writing to the Federal awarding agency or pass-through entity all violations of Federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the Federal award.

I hope you find this blog post helpful as you research, write, apply, and manage grants. If you have any questions or concerns about Subpart B please contact us at www.pksllc.com; we would love to help you out.

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