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Uniform Guidance for Federal Awards

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) is the regulation that replaces OMB Circulars A-21, A-110, and A-133, and it became effective December 26, 2014.

The Uniform Guidance contains the following sections:

  • Subpart A: Acronyms and Definitions
  • Subpart B: General Provisions
  • Subpart C: Pre-Federal Award Requirements and Contents of Federal Awards (previously contained in A-110)
  • Subpart D: Standards for Financial and Program Management (previously contained in A-110)
  • Subpart E: Cost Principles (previously contained in A-21)
  • Subpart F: Audit Requirements (previously contained in A-133)

Updates

Payments to Sub-awardees

Section 200.305(b)(3) indicates that payments to sub-awardees must be made within 30 days unless the invoice is believed to be improper (e.g., deliverables have not been made, the invoice does not meet the requirements of the sub-award). Previously there was no standard for payment. Please make sure that invoices are reviewed and disbursement voucher (DV) e-docs are prepared and approved so that the check/ACH is issued within 30 days of invoice receipt. It is important to retain documentation of any invoice problems or deliverables to substantiate a delayed payment, and this should be noted in the DV. Please work with the Office of Sponsored Programs or Sponsored Financial Services, as appropriate, where problems exist with sub-awardees.

Publication Costs and Period of Performance

Section 200.461(b)(3) permits expenses for project related publications (e.g., page charges) after the period of performance.  However, these charges must be liquidated (i.e., shown as spent on the project account) prior to the project closeout. In practical terms, this limits the applicability of this option to the 60 days following most awards (30 days for most sub-awards).

Resources

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Federal

Higher Education Associations