OMB together with Federal awarding agencies is issuing a joint interim final rule to implement the new guidance at 2 C.F.R. 200 titled Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The rule will be available for public inspection December 18th, published in the Federal register December 19th (at www.Federalregister.gov) and effective for new awards or some funding increments on or after December 26, 2014.
The final guidance and implementing regulations delivers on President Obama’s second term management agenda and his first term directives under Executive Order 13520, the February 28, 2011 Presidential Memorandum, and the objectives laid out in OMB Memorandum M-13-17 to better target financial risks and better direct resources to achieve evidence-based outcomes. The final guidance, which was originally published December 26, 2013 (available at 78 FR 78589) simultaneously improves performance, transparency, and oversight for Federal awards. The COFAR will measure the impact of this guidance as described under M-14-17.
This is the first I’ve heard of this. Where can I find a good summary of the Uniform Guidance and policy changes it includes?
What happens on December 19th and after?
What does the December 19, 2014 Federal Register publication include?
Specifically, the implementing regulation will include the following:
Agency adoption of OMB’s Uniform Guidance: Since the publication of the Uniform Guidance on December 26, 2013, the COFAR has been working with Federal agencies and non-Federal stakeholders to prepare for the December 26, 2014 implementation of the policy. The interim final rule will include formal adoption of the Uniform Guidance by 28 Federal awarding agencies in their respective chapters of Title 2 of the Code of Federal Regulations.
Agency exceptions or additions to the Uniform Guidance: In addition to formally adopting the Uniform Guidance, some agency implementing regulations include exceptions or additions to 2 C.F.R. 200. Agency-specific exceptions do not represent new policy. OMB only accepted exceptions where agencies were able to demonstrate that they were authorized by statute or part of long standing policy. For example, the Corporation for National and Community Service included an exception in their regulation to allow recipients to use Federal funds from other agencies as match or cost share as authorized by 42 U.S.C. 12571(e). Agency additions include further guidance or clarification that some agencies chose to include in their regulations. For example, some agencies specify the agency official responsible for granting exceptions to the Uniform Guidance. To see a cross-walk of agency-specific exceptions or additions, click here.
Conforming changes to other regulations:
Many Federal awarding agencies also revised program-specific regulations to update language and references to be consistent with the Uniform Guidance. These changes will also be reflected in the Federal Register publication.Technical corrections to the The Federal Register publication will also include technical corrections that were made to the Uniform Guidance. Many of these corrections are a result of comments received from non-Federal stakeholders and Federal awarding agencies. These corrections do not represent a change in policy, but are included where is has come to the attention that particular language in the final guidance did not match the intent of the policy.
What happens to my organization on December 26th?
On September 30, 2014, OMB published Memorandum M-14-17 Metrics for Uniform Guidance to measure the impact of the Uniform Guidance and to evaluate the extent to which it achieves the COFAR’s goal of reducing administrative burden and risk of waste, fraud and abuse.
2014 Administrative Metrics
Entire (2 hour) webcast:
• Intro • Session 1: Internal Controls • Session 2: Procurement Standards
• Session 3: Single Audit Reporting • Session 4: Administrative Flexibilities • Session5: Indirect Cost Rates for…
• Intro • Administrative Requirements
(slides available at: COFAR Training Administrative Requirements 1-27-14 Slides)
• Cost Principles • Audit Requirements
Does your organization sponsor training that is relevant to implementation of the Uniform Guidance? If so, please share it here.(link forthcoming)
Improving standardization and transparency has been a priority of the COFAR since its foundation. With the signing of the DATA Act in May 2014, improving Federal spending transparency government-wide has gained a new focus and framework. The COFAR is working with OMB and Treasury Department to successfully implement the DATA Act by serving on the Interagency Advisory Committee (IAC). The IAC examines all aspects of DATA Act implementation and, where necessary, makes recommendations to OMB and Treasury. A representative of the COFAR participates in the IAC and represents the interests of the community in DATA Act implementation. For more information on DATA Act implementation and government-wide work to improve Federal spending transparency, please visit: Federal Spending and Transparency Collaboration Space.
As part of the Digital Accountability and Transparency Act of 2014 (DATA Act) which aims to make information on federal expenditures more easily accessible and transparent. One of the goals is to simplify reporting for entities receiving federal funds by streamlining reporting requirements and reducing compliance costs while improving transparency. The Office of Management and Budget in partnership with the Department of Health and Human Services and the General Services Administration have launched the National Dialogue to reduce reporting compliance costs for Federal contractors and grantees.
The Federal government is looking for ideas on how to reduce the costs (compliance and other) associated with obtaining and managing Federal funds awarded through Federal contracts, grants, or associated subawards. This national dialogue and pilot will be open for the next 24 months to collect suggestions and ideas to iterate potential solutions throughout that process. We welcome and value your thoughts and ideas on improving the Federal procurement and grants processes.
Please click here to begin the dialogue.
What is the Council on Financial Assistance Reform?
The COFAR, established by OMB Memorandum M-12-01, is comprised of an interagency group of Executive Branch officials to coordinate financial assistance. Council activities include providing recommendations to the Office of Management and Budget (OMB) on policies and actions necessary to effectively deliver, oversee, and report on grants and cooperative agreements, as well as sharing with executive departments and agencies (agencies) best practices and innovative ideas for transforming the delivery of this assistance. In addition, the Council will engage relevant stakeholders across Government on key issues to foster more efficient and effective Federal management by coordinating the development and implementation of standardized business processes, data standards, metrics, and information technology. This Council replaces two Federal boards – the Grants Policy Council and the Grants Executive Board to create a more streamlined, flexible, and strategic structure. The Council’s work builds in part on grants streamlining activities under Public Law (P.L.) 106-107, the Federal Financial Assistance Management Improvement Act of 1999. COFAR and CFOC efforts are supported partly by the Financial Management Line of Business.
The membership of the Council on Financial Assistance Reform consists of the:
Controller of the Office of Management and Budget and senior policy officials from eight Federal agencies that provide the largest amounts of financial grants assistance and one additional agency that serves a two-year term to represent the perspective of other agencies that administer grants and cooperative agreements:
Two-year Term Agency