OMB Uniform Guidance 2 CFR Part 200

OMB Uniform Guidance 2 CFR Part 200

The Office of Management and Budget (OMB) recently released Uniform Administrative Requirements, Cost Principles and Audit Requirements (UG) for federal awards intending to reduce the administrative burden and cost of compliance for federal grantees. It introduces reforms and incorporates several important concepts from the current circulars generally providing for more flexibility in the direct charging to federal awards. In doing so, the UG emphasizes the importance of institutional controls that proactively ensures compliance with the terms and conditions of the awards. The Uniform Guidance became effective with all awards issued after 12/26/14 and federal agencies may include them in notice of grant awards on incremental funds. The Uniform Guidance replaces OMB Circulars A21 and A110. Please watch the OVPR website for complete UG guidance information. Of specific importance, we call your attention to the stricter adherence to the federal closeout requirements.

Closeout (200.343) – The UG reinforces that institutions must submit all close-out reports no later than 90 calendar days following the end date of the performance period. In addition to all programmatic reporting, all final costs must be included in the financial closeout report to ensure full reimbursement to the university. The UG allows funding agencies to suspend our ability to draw down cash immediately at the end of the 90 calendar days. For this reason, we will now require that all transactions must be posted to awards within 75 calendar days of project end date. In addition, subaward final invoices from flow through entities, must be received in OGM, within 45 calendar days of project end date. As a reminder, all invoices for subawards must be approved by PI for certification of performance and expenses.

With this in mind our office is developing processes to provide reminders in advance of award termination to facilitate the timely close out. The need to resolve all open transactions and pending payments is essential to our ability to fully recover all costs. 

Office/Topic 
Go to top