The OmniCircular - 2 CFR 200

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1 The OmniCircular - 2 CFR 200 Mary Karen Wills Tina Reynolds September 16, 2014

2 OMB Final Rule and Applicability Office of Management and Budget ( OMB ) issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Final Rule (Uniform Guidance) on December 26, 2013 Referred to as OMB Super Circular or Omni Circular Codified at 2 CFR Part 200 Affects Federal awarding agencies and non Federal entities including non profits, state and local governments, Indian tribes, and Institutes of Higher Education (IHE) that receive Federal assistance awards as a recipient or subrecipient, and their auditors. Note for profit entities will also be subject to certain of these rules. Agencies have 6 months to submit draft implementing regulations to OMB with expectation they will be finalized and effective no later than December 26,

3 Regulatory Harmonization Location in new OMB Circular where existing OMB Circulars are included General Pre Award Post Award Previous Guidance now replaced by SuperCircular Grant Administration A 110 Uniform Administrative Requirements for Awards and Other Agreements with Institutions of Higher Education, Hospitals and Other Nonprofit Organizations A 102 Awards and Cooperative Agreements with State and Local Governments A 89 Federal Domestic Assistance Program Information Cost Principles Audit Cost Principles A 21 Cost Principles for Higher Educational Institutions A 87 Cost Principles for State, Local and Indian Tribal Governments A 122 Cost Principles for Non Profit Organizations Single Audit A 133 Audits of States, Local Governments and Non Profit Organizations A 50 Audit Follow Up 3

4 Navigating 2 CFR CFR Paragraph Sub Title part to A Acronyms and Definitions B General Provisions C Pre Award Requirements D Post Award Requirements E Cost Principles F Audit Requirements Appendices I XI 4

5 Applicability of OMB Final Rule Federal agencies must implement the changes and issue new agency supplements by December 26, 2014 Federal agencies may not impose new requirements prior to December 26, 2014 Applies to Federal assistance awards and to additional funding (funding increments) made after December 26, 2014 Existing awards will continue to be governed by the terms and conditions of their Federal award agreement No retroactive change to award terms and conditions Except, the new single audit guidance will be applied to these awards beginning December 26, 2014 Awardees may make policy and procedural changes to comply with new requirements before effective date. Awardees needing to make entity wide system change to comply after the effective date will not be penalized for doing so. Single audit changes are effective for fiscal years beginning after December 26,

6 Goals Provide a government-wide framework for grants management Ensure that discretionary grants and cooperative agreements are awarded based on merit Reduce administrative burden for non-federal entities receiving federal awards minimizing time spent on compliance Increase focus on performance outcomes Streamline and clarify guidance on subrecipient monitoring Reduce risk of waste, fraud, and abuse 6

7 Critical New Areas Included The following areas are those where requirements differ fairly significantly from existing regulatory guidance, and should be a primary area of focus as awardees implement the new regulations: Subrecipient definition clarity provided for subreceipient v. vendor v. contractor determination Profit Reaffirmation that profit is not allowed on assistance awards unless specific contract terms address allowable profit Certifications new certifications required from awardees relative to propriety of reported expenditures and payment requests, and related to indirect rate determination, including unallowable cost segregation Mandatory Disclosure Requirements NICRA/Indirect Rate Process Options Fixed Awards Cost Sharing and Time and Effort Reporting Procurement and Property Standards Sub Recipient Monitoring 7

8 Key Concepts Federal Award Federal Awards include: Federal Financial Assistance Awards Grants Principal purpose is to transfer something of value to carry out a public purpose of support or stimulation (not to acquire goods or services for Federal agency) Does not involve substantial involvement of Federal agency Cooperative Agreement Same purpose as grants, but does have substantial involvement from Federal agency Cost Reimbursable contracts awarded to an NGO or University under the FAR and cost reimbursable subcontracts under these contracts in accordance with the FAR Does not include procurement agreements that a Federal agency uses to buy goods and services from a contractor 8

9 Key Concepts - Contractor vs. Subrecipient vs. Vendor Existing guidance led to confusion and unclear definitions of subrecipients vs. vendors, and subawards vs. subcontracts New Definitions: Contractor term Vendor no longer used (replaced by Contractor ) Provides goods or services ancillary to the project scope Provides similar items to other customers Follows a procurement relationship Subrecipient (i.e., subawardee or subcontractor) Carries out part of a Federal award activity, part of project scope Subject to Federal program compliance requirements Performance is measured against objectives of Federal program Makes own decisions on how to carry out responsibilities 9

10 Key Concepts - Contractor vs. Subrecipient vs. Vendor Non Federal entities may receive funding as a subrecipient or as a contractor The substance of the award determines the treatment, regardless of the name used to refer to the award agreement If the awardee meets the definition of a subrecipient, it must comply with the provisions applicable to a subrecipient regardless if the pass through entity calls it a subcontract If the awardee meets the definition of a contractor, it must comply with the provisions applicable to a contractor regardless if the agreement is referred to as a vendor agreement or subcontract or subreceipient 10

11 New Ethics Requirements Conflict of interest Now mandate that federal awarding agencies must have conflict of interest procedures in place Non-Federal entities must disclose conflicts of interest to awarding agency or pass through entity Mandatory disclosures Non-Federal entities must disclose to the awarding agency or pass through entity violations of law involving fraud, bribery, or gratuity violations potentially affecting the award. Penalties for non-disclosure can include: Withholding of payment Termination of award Suspension or debarment Certification Must now certify knowledge of statutory consequences of false certification of costs 11

12 Overarching Compliance Requirements - Conflicts of Interest Awarding agencies must establish conflict of interest policies Conflict of Interest Section: Conflict of interest definitions have been removed to permit awarding agencies to have specific policies tailored to the specific nature of their programs potential for disparity in Federal agency guidance * Organizations (non Federal agencies) must disclose in writing to Federal awarding agency (or pass through entity) any actual or potential conflicts of interest 12

13 Pre Award Federal Agency Risk Review Federal Agency Pre Award Risk Review Section: Agency will perform risk assessment for a potential awardee, and includes: Financial capability Quality of management systems History of performance (past performance reviews) Agency report and/or findings from Single Audit Ability to implement regulations, terms & conditions Prior debarment or suspensions Depending on results of risk review, special award conditions may be required by Federal agency Special award conditions could apply, such as: Restricting advances Withholding approvals (require special approvals) Requiring additional reporting or monitoring Requiring additional technical or management assistance 13

14 Pre Award Fixed Amount Awards Fixed Awards Section: Fixed Awards are now encouraged Fixed Award is a type of grant where the awardee performs a specific level of effort for a fixed price, without regard to cost incurred (similar to a fixed price contract) Reduces recording keeping No review of incurred costs, except in termination situation In amounts up to $150,000 (Simplified Acquisition Threshold) Can only be used when project scope is specific and adequate price / cost data is available to assure that no fee will be earned. Awardee (prime) must have prior written approval from Federal awarding agency to issue a fixed amount subaward Awardee must certify to Federal awarding agency or pass through entity at end of Federal award that the project was completed or the level of effort was expended. If not, the amount of the Federal award must be adjusted. Cannot be used if there is mandatory cost share requirement 14

15 Post Award Systems and Controls Financial Management Rejected suggestion of separate bank account for each award Documentation and record-keeping standards Section: Internal Controls Entity responsible for protection of personally identifiable information (PII) Cost-Sharing Considerations Voluntary cost sharing is not expected and cannot be used as a factor during merit review Monitoring and Reporting More specific language to encourage evidence-based program design. 15

16 Post Award Systems and Controls Organizational Conflicts of Interest Section: Record Retention Still three years from submission of final expenditure report Termination Termination for convenience now available Closeout days to submit all final reports Closeout timeframe has been extended to one year (beginning upon receipt of final reports) 16

17 Post Award Period of Performance Period Of Performance Section: Allowable costs may be charged to the award during the period of performance only. Allowable pre award costs that were authorized by Federal awarding agency or by the pass through entity are still reimbursable. Federal agencies may still allow no cost extensions to the period of performance 17

18 Post Award - Procurement More Rigorous Procurement Standards (adopted language of A 102) Sections: Increased awardee procurement documentation requirements Must maintain a history of [all] procurements including the rationale for the method, contract type, contractor selection and basis of price 5 procurement methods provided to awardees: Micro purchases up to $3,000 (no competition) Small purchases Raised to $150,000 Simplified Acquisition Threshold Sealed Bid (typically for contracted goods and services) Competitive Bid Noncompetitive in limited circumstances ( sole source ) Limits awardees use of T&M procurements To be used when no other option is suitable Awardee is required to provide cost or price analysis for procurements in excess of $150,000 18

19 Post Award Subrecipient Monitoring NOTE: Pass through entities must make an individual determination of contractor vs. subrecipient ( ) Subrecipient Monitoring (does not apply to contractors ) Sections: Requires the following to be included in subawards CFDA number, flow down clauses, agency name, award name, award year, etc. Flow down of all requirements by pass through entity Terms and conditions for subaward close out Statutory and national policy requirements (such as small business use) Pass through entity must accept subrecipient s approved negotiated indirect rate, or if subrecipient does not have an approved negotiated rate, negotiate one with the subrecipient, or permit a flat rate of 10% 19

20 Post Award Subrecipient Monitoring Subrecipient Monitoring (does not apply to contractors ) Sections: Awardees (prime) must assess risk of each subrecipient to determine appropriate monitoring and oversight activities Must use same criteria as provided to Federal agencies when performing risk assessment on pass through entities Must use monitoring techniques including: training and technical assistance, on site reviews, agreed upon procedures audits, Single Audit report reviews, etc. Awardees (prime) must: Review financial and programmatic reports Issuance of a management decision for audit findings (and onsite review findings) related to subrecipient deficiencies Subrecipient must allow access to its books and records and financial statements to enable prime and or Federal agency to perform its monitoring responsibilities. NOTE: The increase in the Single Audit threshold to $750,000 will reduce number of subrecipients with A 133 audit reports 20

21 Implications for Pass-Through Entities Procurement standards Written standards of conduct covering personal and organizational conflicts of interest Maintain records detailing procurement history Full and open competition; eliminate unfair competitive advantages Follow specified methods of procurement Take affirmative steps to use minority businesses, women s business enterprises, and labor surplus area firms when possible Perform a cost/price analysis for every procurement action in excess of Simplified Acquisition Threshold (including contract modifications) Make technical specifications and procurement documents available for review Subrecipient monitoring requirements Risk evaluation Activity monitoring, including review of financial and programmatic reports Audit verification 21

22 SUBPART E COST PRINCIPLES 22

23 Selected Cost Principles General Provisions and Application General Provisions and Application Section: To be charged to the government, costs must be reasonable, allowable, and allocable. Cost principles do not apply to fixed amount awards, only those where tracking of actual costs is required. Some non-profits, by nature of their size and operations, are subject to FAR Part 31 cost principles instead. Major addition to overall policy: Makes explicit that non-federal entities may not earn or keep any profit resulting from federal financial assistance, unless expressly authorized by the terms and conditions of the award 23

24 Selected Cost Principles Profit Profit and Program Income Section: The OMB added new language clarifying that an awardee may not earn or keep profit resulting from Federal financial assistance awards, unless expressly authorized by the terms and conditions of the award Guidance is intended to make this long standing requirement explicit for the purposes of accountability and oversight Prior guidance has always required costs to be reasonable, allocable and allowable and excluded any additional increment for profit beyond cost 24

25 Selected Cost Principles NEWLY ADDED Cost Principles Exchange Rates ( ): Cost increases for fluctuations in foreign exchange are allowable subject to the availability of funding and prior approval from the awarding agency Newly Added Cost Principles Collection of Improper Payments ( ) Costs to recover improper payments are allowable (direct or indirect). Includes costs to recover overpayments, double payments, incorrect payments, etc. Proposal Costs ( ): Costs of preparing bids, proposals, or applications on potential Federal and non Federal awards or projects are allowable Includes the development of data necessary to bid Includes successful and unsuccessful proposals Treated as an indirect cost 25

26 Selected Cost Principles - Required Certifications Provides explicit and consistent language to ensure that expenditures are proper and in accordance with the terms and conditions of the award and approved budget Required Certifications Section: Used for annual and final fiscal reports, vouchers requesting payment and incurred indirect cost claims References False Claims language Signed by an official authorized to legally bind the entity By signing this report, I certify to the best of my knowledge and belief that he report is true, complete, and accurate and the expenditures, disbursements and cash receipts are for the purposes and objective set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious or fraudulent information or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statement, false claims or otherwise. 26

27 Selected Cost Principles Compensation Compensation for Personal Services Section: Includes all pay (current and accrued) for the current period Must be: Reasonable (consistent and/or comparable) Consistently applied across organization Conform to written policies Supported by time keeping records Unallowable if in excess of statutory ceilings * Incentive Compensation must be based on written plan and based on objective measures such as cost reduction targets, performance measures, etc. * NOTE: Bipartisan Budget Act set the reimbursable compensation ceiling for contractor and subcontractor employees working on a Federal program at $487, Agencies may have limits at a lower level For example: the salary limitation for NIH grant and cooperative agreement awards and extramural research and development contract awards restricts the amount of direct salary to $181,500 effective January 12,

28 Selected Cost Principles Direct and Indirect Costs Organizations that have never received a negotiated indirect cost rate can negotiate an indirect cost rate agreement (NICRA) or elect a flat rate of 10% (a Modified Total Direct Cost F&A rate) Direct and Indirect Costs Sections: Federal agencies must accept an awardees' approved NICRA and a prime awardee must accept a subawardee s approved NICRA Exceptions are only permitted if required by statute, regulation or if specifically approved by the Federal awarding agency head or delegate based on publicly documented justification Federal awarding agency must notify OMB of exception Permits a one time extension of current NICRA rates for a period of up to 4 years (i.e., use same rates for up to 4 years) Subject to review and approval by cognizant agency May be for periods less than 4 years Use caution as business factors may change during period 28

29 Selected Cost Principles Direct and Indirect Costs Direct and Indirect Costs Sections: Organizations permitted to direct charge administrative support costs that are normally considered indirect when: Administrative support services are integral to program Effort can be specifically identified to program Costs are included in budget or have advance written approval Costs are not also recovered as indirect Any direct cost of a minor amount may be treated as an indirect cost for reasons of practicality Minor amount is not defined Must be consistently applied across all Federal and non Federal cost objectives 29

30 Selected Cost Principles Cost Share Voluntary cost sharing cannot be used as a merit factor in a research proposal unless it is required in the Federal agency regulations and specified in the funding notice Cost Share / Matching Sections: Mandatory cost sharing or cost sharing committed in the project budget must be included in the indirect cost allocation base Cost Share must be: Allowable and verifiable Not included as a contribution in another award Necessary and reasonable to accomplish award Not paid for elsewhere In the approved budget when required by Federal agency Depreciation as cost share Organization can claim depreciation either as a depreciation expense OR cost share / matching, BUT NOT BOTH Must exclude from acquisition cost the portion of cost of the buildings and equipment that were donated, or where law or agreement prohibits recovery 30

31 Selected Cost Principles Other Definition of Computing supplies ( ) Computer equipment up to $5,000 (or lesser of capitalization policy) can now be treated as supplies (no need to track) Other Key Items Collection of Unallowable Costs ( ) Payments made for costs subsequently determined to be unallowable must be refunded including interest Excess Severance ( ) Severance in excess of awardee policy is unallowable Conferences ( ) Costs of identifying but not providing locally available dependent care options for conference attendees is allowable 31

32 Selected Cost Principles Other Other Key Items Contingency Costs ( ) Unallowable except for certain employee compensation related expenses (i.e., severance) Although allowed in award budget, expenditures are not allowable until paid and incurred Employee Health and Welfare ( ) Costs incurred according to awardee s policy for the improvement of workplace, employer employee relations, employee health and employee performance are allowable Removed morale to avoid potential confusion with rules on entertainment costs Idle Facilities ( ) Idle facility costs necessary to meet fluctuations in workload are allowable 32

33 Selected Cost Principles Other Other Key Items Interest ( ) Interest incurred on financings associated with patents and/or computer software is allowable but only for the portion capitalized under GAAP Eliminated requirement to justify large capital purchases Eliminated requirement to perform lease vs. buy purchase analysis to justify external bond interest Applies to both IHEs and NFPs Relocation Costs ( ) Costs to carry a relocated employee s vacant home limited to 6 months 33

34 Selected Cost Principles Other Other Key Items Student Activity Costs ( ) Expanded to apply to all awardees Costs incurred for intramural activities, student publications, student clubs and other student activities are allowable unless excluded by an award Value Added Tax ( ): Value added taxes on purchases of goods or services that the awardee is legally required to pay are allowable 34

35 Selected Cost Principles Other Travel Costs ( ) Temporary dependent care costs above regular dependent care costs that result from travel to conferences is allowable provided it is consistent with awardee s policy and is limited to the travel period Other Key Items Areas where prior written approval is recommended OMB lists 22 circumstances under which an awardee should seek prior approval to avoid subsequent disallowances or disputes Includes, but not limited to: Program income Travel Exchange Rates Fixed amount subawards Compensation Memberships Participant Support Costs 35

36 Key Implementation Priorities Guidance will continue to emerge, especially as individual agencies issue their supplements Review Organizational and Personal Conflict of Interest Policies Need to examine existing code of conduct and policies related to Conflicts of Interest Assess gaps and needed changes Is it written? Does it cover actual and potential conflicts Does it cover personal and organizational conflicts? Is it clear? Are employees trained? Does it extend to board members, officers, agents, subrecipients, etc.? Examine Federal awarding agency(ies) conflict of interest policies Does the organization policy confirm to each agency s standard? Will the agency(ies) be updating their policies in light of new Super Circular? 36

37 Key Considerations and Implementation Priorities Internal Controls Develop and design internal controls to meet award and compliance requirements, leveraging best practices Need to develop related policies and procedures Need to identify gaps, prioritize remediation and self monitoring activities Need to align compliance and internal audit activities with updated COSO framework Assess and plan for accounting practice, system and reporting changes Identify any changes to disclosed accounting practices Plan for advance notice periods Universities now have 6 month advance notice requirement Perform initial assessment of change to capture and report performance metrics and outcome measures and cost impact Assess need for performance monitoring and evaluating systems Understand impact of establishing, tracking progress and reporting on achievement of performance measures Determine needed processes and system changes to facilitate providing invoice certifications 37

38 Key Considerations and Implementation Priorities Organizations will need to develop/update core written policies and procedures: Advance Payments, including minimizing time outstanding for advances ( ) Determining Cost Allowability ( ) Internal Controls ( ) Procurement ( and ) Conflict of Interest ( , ) Code of Conduct ( ) Effort Reporting (Labor Distribution and Reporting) ( ) Leave ( ) Pension and Employment Insurance ( ) Relocation ( ) Employee Health and Welfare ( ) Employee Travel Reimbursement ( ) Subrecipient Monitoring ( ) Cost Share ( ) Subrecipient vs. Contractor (200.23, ) Training Develop change management and training programs for staff and managers 38

39 Key Considerations and Implementation Priorities New Certifications Awardees should assess current processes to determine if they will provide them with the assurances required to offer the new certifications they will be required to submit. Award Expenditures ( (a)) and Indirect Rates ( (b)) Likely awardees will need new stronger policies around propriety of expenditures, segregation of unallowable costs, and determination of indirect costs Mandatory Disclosures Awardees should assess processes designed to report to management potential or actual violations, issues and errors 39

40 Key Considerations and Implementation Priorities Time and Effort Reporting Assess written policies and procedures for time and effort reporting against compliance requirements. Identify gaps and needed changes. Develop robust tracking mechanism to capture direct charge effort by indirect staff. NOTE: Unclear how the use of time/effort reporting estimates during billing cycles aligns with the new required certifications Subrecipient Administration and Monitoring Assess current subrecipient administration processes against compliance requirements Design subrecipient risk assessment review process and methodology for including special award provisions Assess subrecipient monitoring program against compliance requirements and prioritize remediation activities Small Business Focus Assess small business compliance program and identify gaps and activities to document compliance with enhanced requirements 40

41 Locating 2 CFR Part 200 and Relevant Resources Federal Register Final Rule /uniform administrativerequirements cost principles and audit requirements for federal awards 2 CFR Part 200: ecfr Code of Federal Regulations bin/textidx?sid=704835d27377ef5213a51c149de40cab&node=2: &rgn=div5 OMB website: The Following are accessible through the OMB Website OMB Policy Statements: Uniform Grant Guidance Uniform Guidance Crosswalk from Existing Guidance to Final Guidance Uniform Guidance Crosswalk from Final Guidance to Existing Guidance Cost Principles Comparison Chart 2 CFR Part 225 (A 87), 2 CFR Part 220 (A 21), 2 CFR Part 230 (A 122) and Final Uniform Guidance Audit Requirements Comparison Chart OMB Circular A 133 and Proposed Uniform Guidance Subpart F Definitions Comparison Chart Administrative Requirements Comparison Chart COFAR FAQs to SuperCircular of federal grants policies 2/ 41

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