2CFR 200 Uniform Administrative Requirements, Cost Principles, and

Audit Requirements for Federal Awards

Presented by: Dan Parker/FHWA

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)

Introduction to 2 CFR Part 200 “Uniform Guidance”

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

Introduction to 2 CFR Part 200 “Uniform Guidance”

2 CFR 200- Introduction

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

Applicability of the “Uniform Guidance”

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

Definitions

Subpart A §200.0-200.99

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- Post Award Requirements

Subpart D §200.300-200.345

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

Performance Measurement

Subpart D §200.300-200.345

Consider them Earlier in the Process Provide Reasonable Assurance Exercise Judgment - Appropriate and Cost

Effective based on the circumstances Safeguard Personally Identifiable Information

(PII)

Greater Focus on Internal Controls

Subpart D §200.300-200.345

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

Payments

Subpart D §200.300-200.345

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

Period of Performance

Subpart D §200.300-200.345

Subawards include required data elements and requirements

Pre-award Risk Assessment Risk Based Oversight Framework Monitor the activities of the subrecipient

Sub-recipient Monitoring

Subpart D §200.300-200.345

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

Project Closeout

Subpart D §200.300-200.345

Cost Principles

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

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

Audit Requirements

Subpart F §200.500-200.521

§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

Other Requirements and Deviations

2 CFR 200- Deviations

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

Frequently Asked Questions

Resources

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 Centerhttp://www.fhwa.dot.gov/pgc/

2 CFR 200 Implementation Guidance