1. OMB Super Circular Big Changes for Nonprofits

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

3. 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

4. Who?
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

5. 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

6. 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 – Fund-
raising costs for the purposes of meeting
the Federal program objectives are
allowable with prior written approval
from the Federal awarding agency.

7. 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

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

9. Where to Find It Topic Page in NOA Circular Non-entity Responsibility
2 CFR
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 and
Record Keeping
Page 11
2 CFR
Project Close Out
Page 18
2 CFR
Disposition of Equipment
Page 19
Prior Approval Requirements
2 CFR

10. 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
Indirect Costs Rate Agreements
Page 28
2 CFR
Matching Contributions
Page 29
2 CFR
Program Income
Pages 30 and 33
2 CFR and 307