OMB Super Circular Big Changes for Nonprofits

OMB Super Circular Released 12/26/2013 2 years of study, 2 drafts Goal: Better Management of Federal Funds 2 CFR Part 200

From 8 to 1 OMB Super Circular combines 8 grant related circulars into 1 document, supersedes current: A-133 A-110 & A-122 A-21, A-87 & A-89 A-102 Sections of A-50

Who? 200.101 Super Circular applies to federal agencies that make federal awards to non-federal entities Flows down to sub-awards to sub recipients unless specifically excluded in Super Circular Nonfederal entities must comply with Super Circular regardless of whether they are recipients or sub recipients

Effective When? Effective on publication 12/26/2013 Federal agencies must release regulations 6/26/2014 Federal agencies must implement the Super Circular to be effective 12/26/2014 Audit requirements will apply to audits of fiscal years that start on or after 12/26/2014

Major Super Circular Changes Audits – Audit expenses may not be charged to the grant as a direct cost (Federal nor non-Federal). The expenses may only be charged as an indirect cost. If audit expenses were included in your application as a direct cost, the budget MUST be revised to remove those costs and used for other allowable costs. Fundraising – Under 200.442 – Fund- raising costs for the purposes of meeting the Federal program objectives are allowable with prior written approval from the Federal awarding agency.

Prior Written Approval 200.407 Now grouping of all prior approval requirements are in one regulation Absence of prior approval will not affect reasonableness or allocability determination unless prior approval was specifically required

Internal Controls Controls designed and implements to: Prevent fraud, waste and abuse Protect personally identifiable information

Where to Find It Topic Page in NOA Circular Non-entity Responsibility 2 CFR 200.303 Administrative Requirements and Post Federal ward Requirements Page 9 2 CFR Part 200, Sub Part D, Sub granting and Sub Contracting (Not Allowed) 2 CFR 200.318-323 and 200.26 Record Keeping Page 11 2 CFR 200.314 Project Close Out Page 18 2 CFR 200.343 Disposition of Equipment Page 19 Prior Approval Requirements 2 CFR 200.407

Where to Find It (con’t) Topic Page in NOA Circular Cost Principles Page 26 2 CFR 200, Sub Part E Liability, Indemnification, Insurance Costs Page 27 2 CFR 200.447 Indirect Costs Rate Agreements Page 28 2 CFR 200.414 Matching Contributions Page 29 2 CFR 200.306 Program Income Pages 30 and 33 2 CFR 200.305 and 307