New OMB Uniform Guidance (2 CFR 200)
On December 26, 2013, the Office of Management and Budget (OMB) issued the Uniform Administrative Requirements, Cost Principles and Audit Requirements (Uniform Guidance or 2 CFR 200). The Uniform Guidance (UG) streamlines and supersedes guidance previously contained in eight separate OMB Circulars. For Institutions of Higher Education, like the University of Miami, the UG supersedes OMB Circulars A-110, A-21 and A-133. Included in the new guidance are uniform administrative requirements (pre and post award), cost principles, audit requirements and definitions. The effective date is December 26th, 2014 for all federal awards or funding increments provided on or after this date and FY2016 for audit. Existing federal awards received prior to December 26, 2014 will continue to be governed by the terms and conditions under which they were awarded.
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
The Uniform Guidance is broken down into Subparts. It also contains a preamble that provides the purpose and background as to how certain guidelines were ultimately determined.
Preamble - Major Policy Reforms
Subpart A - Acronyms and Definitions
Subpart B - General Provisions
Subpart C - Pre Award Requirements
Subpart D - Post Award Requirements
Subpart E - Cost Principles
Subpart F - Audit Requirements
Appendices - Some of the rules were not incorporated into the consolidated set of guidance, but rather remained applicable only to a specific type of entity. These rules are incorporated into the appendices. Appendix III is applicable to Institutions of Higher Education.