New rules effective for federal awards made after December 26, 2014
In December 2013, the US Office of Management and Budget (OMB) issued comprehensive grant reform rules titled “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.” The new requirements consolidate what was previously in eight separate OMB Circulars into a single new document. This consolidation resulted in various areas of change to the previous requirements.
As discussed in previous newsletter articles, the grant reform rules are intended to streamline the federal government’s guidance on administrative requirements, cost principles, and audit requirements for federal awards. The final guidance supersedes OMB Circulars A-21, A-50, A-87, A-89, A-102, A-110, A-122, and A-133.
As of August 2014, Baker Tilly has found that federal award recipients are at very different stages of their implementation progress. Generally, the higher education industry has made more substantial progress in analyzing the impact of the reform and implementing necessary policy and procedure changes. State and local government and not-for-profit recipients seem to be slower in their analysis and implementation.
If you receive federal grant awards and have not yet analyzed the impact of the change, now is the time to act. The new rules take effect with federal awards made after December 26, 2014 (including additional funding increments to existing awards).
In addition, the Council on Financial Assistance Reform (COFAR) will also be issuing documents with frequently asked questions related to the grant reform. The first of these documents, Frequently Asked Questions for New Uniform Guidance at 2 CFR 200, was issued on February 12, 2014. A second document is anticipated to be issued later summer or early fall.
For a closer look at this topic, view a replay of our webinar from earlier this year, “OMB Grant Reform: An overview of the recent changes and tips to help ensure your compliance.”
For suggestions on planning for these changes, view a replay of our second recent webinar, “OMB Uniform Grant Guidance: Developing a Successful Implementation Plan” and download a roadmap for implementation.
For more information on this topic, or to learn how Baker Tilly state and local government specialists can help, contact our team.