Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

SAMHSA grants webpages are currently being updated to reflect the new guidance effective December 26, 2014.

The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards is the final revised rule streamlining grant management requirements. This guidance supersedes requirements from OMB Circulars A-21, A-87, A-110, and A-122 (which have been placed in OMB guidances); Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up. HHS Codified 2 CFR 200 in its regulations at 45 CFR 75. The Uniform Guidance is effective as of December 26, 2014.

Repealed, effective 12/26/14

New, effective 12/26/14

Administrative Requirements:

2 CFR 200/45 CFR Part 75

"Uniform Administrative Requirements,
Cost Principles, and Audit Requirements
for HHS Awards"

45 CFR 74/
2 CFR 215

Higher educations, hospitals, other non-profits

45 CFR 92

State, local, and tribal governments

Cost Principles:

2 CFR 220
OMB Circ. A-21

Institutions of higher education

2 CFR 225/
OMB Circ. A-87

State, local, and tribal governments

2 CFR 230/
OMB Circ. A-122

Non-profit organizations

2 CFR 215/
45 CFR 74 App. E

Hospitals

Audits:

OMB Circ. A-133

States, local governments, and non-profits

Uniform Grant Guidance

Guidance Comparisons: Uniform Grant Guidance Crosswalks and Side-by-Sides

Key policy reforms in the Uniform Guidance will:

  • Allow state, local, and tribal governments to work in partnership with universities and non-profits to design the programs that best meet their local communities’ needs and obtain flexibility and enhanced coordination from the federal government
  • Allow nonprofits and other organizations that have never been reimbursed for indirect costs to use a standard minimum rate that supports the fundamental operations of the organization; removing a key barrier to entry and opening up competition for federal awards
  • Publish Single Audit reports online, eliminating a burdensome paper-chase for reporting and providing the public with key information to strengthen oversight of federal tax dollars
  • Raise the threshold for required audits from $500,000 to $750,000 in federal awards expended per year, maintaining oversight for 99% of dollars audited now, but focusing the resources to reduce risk of waste, fraud, and abuse
  • Emphasize the long-standing requirement for non-federal entities to have strong internal controls that are appropriate to the organization, while relaxing overly prescriptive and obsolete procedural requirements

What Do Current Grantees Need to Know?

The effective date is covered in section 200.110, Effective/applicability date.

  • Federal agencies must implement the requirements to be effective by December 26, 2014.
  • Subpart F, Audit Requirements, will apply to audits of non-federal entity fiscal years beginning on or after December 26, 2014. The revised audit requirements are not applicable to fiscal years beginning prior to that date.
  • Administrative requirements and cost principles will apply to new awards and to funding increments, in cases where the federal agency considers funding increments to be an opportunity to modify the terms and conditions of the federal award, to existing awards made on or after December 26, 2014.
  • Existing federal awards that do not receive incremental funding with new terms and conditions will continue to be governed by the terms and conditions of the federal award.

Will this apply only to awards made after the effective date, or does it apply to awards made earlier?

  • Once the Uniform Guidance goes into effect for non-federal entities, it will apply to federal awards or funding increments after that date, in cases where the federal agency considers funding increments to be an opportunity to modify the terms and conditions of the federal award. It will not retroactively change the terms and conditions for funds a non-federal entity has already received.
  • We would anticipate that for many of the changes, non-federal entities with both old and new awards may make changes to their entity-wide policies (for example, to payroll or procurement systems). Practically speaking, these changes would impact their existing/older awards. Non-federal entities wishing to implement entity-wide system changes to comply with the Uniform Guidance after the effective date of December 26, 2014 will not be penalized for doing so.
Last Updated: 01/09/2015