1. 2 CFR 200-
aka Uniform
Guidance

2. What is the Uniform Guidance?
The Office of Management and Budget (OMB) has combined 8 federal circulars into a single document known as Uniform Guidance.
The Council on Financial Assistance Reform (COFAR) was delegated the responsibility of developing the Uniform Guidance, with the goal of reducing administrative burden while improving oversight and accountability.
Addresses the administration’s goal of a government that is more efficient, effective and transparent.
Strengthens requirements for INTERNAL CONTROLS while providing administrative FLEXIBILITY for non-Federal entities.
The Uniform Guidance applies to new awards and incremental funding to existing awards made on or after 12/26/14.

3. Administrative Requirements
What
changed?
A-50
Guidance for federal awards were spread over these 8 circulars.
Uniform Grant Guidance: Title 2 of CFR, Subtitle A, Chapter II, Part 200

4. Administrative Requirements
Combined all related OMB guidance into one location (2 CFR 200)
Administrative requirements (A-102, A-110)
Federal cost principles (A-21, A-87, A-122)
Single audit (A-133, A-89, parts of A-50)
According to COFAR, this eliminated about 80 pages “of overlapping, duplicative, and conflicting provisions”

5. “Eliminating” 80 Pages

6. Structure of Uniform Guidance
Located at 2 CFR 200
Contents
Subpart A – Acronyms and Definitions
Subpart B – General Provisions (200.1xx)
Subpart C – Pre-Award Requirements (200.2xx)
Subpart D – Post-Award Requirements (200.3xx)
Subpart E – Cost Principles (200.4xx)
Subpart F – Audit Requirements (200.5xx)
Appendices I - IX
Code of Federal Regulations
Higher Ed
Nonprofits
Indian tribes
Appendix 1 – notice of funding opportunity
Appendix II – Contract provisions (boilerplate)
Appendix X – Data Collection Form
Appendix XI – Compliance Supplement

7. Significant Changes Changes in organization/terminology
Internal control requirements
New procurement standards
Subrecipient monitoring/management
Minor changes to cost principles
Numerous changes to single audit requirements

8. 2 CFR Pre-Award Cost
Uniform Guidance: Pre-award costs are those incurred prior to the effective date of the Federal award in anticipation of the Federal award where such costs are necessary for efficient and timely performance of the scope of work. Such costs are allowable only to the extent that they would have been allowable if incurred after the date of the Federal award and only with the written approval of the Federal awarding agency.
US FWS – Sport Fish Restoration Grant Program CFDA Number: NOFO F16AS00048: Estimated costs to attain the objectives – The various activities or components of each project should be broken down by cost and by cooperator;
Texas’ US FWS Region – Originally required that exact cost for pre-agreement cost be submitted with the application. After discussions, they have accepted estimated cost.

9. INTERNAL CONTROLS Section 200.303
Recipients of federal funding must:
Establish and maintain effective internal controls that provide reasonable assurance that you are managing awards in compliance with Federal statutes, regulations and the terms and conditions of the award.
Evaluate and monitor compliance and take prompt action when instances of non-compliance are identified
Take reasonable measures to safeguard protected personally identifiable information

10. 200.306 Cost Sharing or Matching (Equipment Rates)
(h) The method used for determining cost sharing or matching for third-party- donated equipment, buildings and land may differ according to the purpose of the Federal award.
Federal Agencies have latitude for interpretation:
USFWS interprets this to mean rates of depreciation or regional USACE rates can be used by sub-recipients
VS.
FHWA interprets this to mean that easy to use FEMA rates can be used by all
Recommend that NPS allow utilization of FEMA rates by Pass-through entities and Sub-Recipients.

11. REVISION OF BUDGET & PROGRAM PLANS Section 200.308
The following budget or program deviations require prior approval from the federal agency:
Change in scope or the objective of the program
Change in a key person specified in the application
Inclusion of costs that require prior approval
Transfer of funds budgeted for participant support costs
Sub awarding or contracting work out unless described in the application

12. PROCUREMENT Sections 200.317 through 326
The UG provides detailed methods to procure goods and services when funded by a federal award which includes stricter requirements for sole-source purchases. The UG emphasizes the documentation requirements and internal written procedures for procurement.

13. 2 CFR 200.328 Monitoring and Reporting Program Performance
You are responsible for oversight of the operations of the Federal award supported activities. You must monitor its activities to assure compliance with Federal requirements and performance expectations are being achieved. Monitoring by the non-Federal entity must cover each program, function or activity.
Construction performance reports. Onsite technical inspections and certified percentage of completion data are relied on heavily by Federal awarding agencies to monitor progress under Federal awards and subawards for construction. The Federal awarding agency may require additional performance reports when considered necessary.
Texas’ USFWS Region :
No specific form or format required to complete the Interim Performance Report or the Final Performance Report.
No guidelines on certified percentage of completion data.
Each state within the Region has their own form and provides its percentages based on their processes.

14. REQUIREMENTS FOR PASS-THROUGH ENTITIES Section 200.331
Includes a standard list of information that must be included in all sub awards (longer more detailed grant agreements)
Requires us to perform a risk assessment of subrecipients prior to issuing subagreements to determine the appropriate level of monitoring. The UG provides the critieria for determining risk, which includes prior experience and audit results

15. TPWD Risk Assessment Guidance

16. TPWD Risk Assessment Guidance

17. TPWD Risk Assessment Guidance

18. TPWD Risk Assessment Guidance

19. TPWD Risk Assessment Guidance

20. TPWD– Sample Risk Assessment

21. TPWD– Sample Risk Assessment

22. TPWD– Sample Risk Assessment

23. TPWD– Sample Risk Assessment

24. TPWD– Sample Risk Assessment

25. TPWD– Sample Risk Assessment

26. TPWD– Sample Risk Assessment

27. TPWD– Sample Risk Assessment

28. TPWD– Sample Risk Assessment
External sources referenced:
SAM (System of Award Management) results
FAPIIS (Federal Awardee Performance & Integrity Info System) results
Federal Audit Clearinghouse SF-Single Audit Report

29. Increased Administrative Burden
2 CFR 200 was intended to streamline regulations…
In reality it has dramatically increased Administrative Burden on our staff
Each federal agency may implement a slightly different version of the UG

30. Challenges with implementing the Uniform Guidance
Language in the Uniform Guidance is open ended
Focus on effectiveness of internal controls
Non-Federal Entities required to maintain written policies
Policies surrounding cash management and subrecipient risk assessments
Challenges in evaluating controls & processes to determine adequacy
Need to develop new forms and procedures at state level
Time to understand and negotiate administrative requirements with federal partners

31. Challenges with implementing the Uniform Guidance
Pushing down new requirements to sub awardees
Varying levels of expertise and sophistication of sub awardees
Impact of changes on your internal agency structure
More time and resources needed to meet inspection requirements
Lack of administrative funding from feds to meet new requirements
Need for additional FTE and other operating resources??