Uniform Admin Requirements For Federal Grants

PARTICIPANT GUIDE
Uniform
Administrative
Requirements for
Federal Grants
2 CFR 200 (SUBPARTS A
THROUGH D)
Management Concepts
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Uniform Administrative Requirements for Federal Grants: 2 CFR 200 (Subparts A through D)
Course #: 2050
Version: 18-11-14
UNIFORM ADMINISTRATIVE REQUIREMENTS FOR FEDERAL GRANTS
TABLE OF CONTENTS
Syllabus ............................................................................................................................ 11
Course Overview ............................................................................................................. 11
Who Takes This Course ............................................................................................... 11
Learning Objectives ...................................................................................................... 11
Prerequisites ................................................................................................................ 12
Course Expectations ........................................................................................................ 12
Required Texts ............................................................................................................. 12
Course Schedule .......................................................................................................... 13
Requirements for Successful Completion ..................................................................... 14
Professional Benefits ....................................................................................................... 14
Module 1: Introduction to the Uniform Administrative Requirements ....................... 19
Lesson 1: Significance and Applicability of the Uniform Administrative Requirements ......... 21
1.1 Significance of the Uniform Administrative Requirements ...................................... 21
1.2 The Importance of Compliance .............................................................................. 24
1.3 "Should" versus "Must" .......................................................................................... 25
Lesson 2: History of the Uniform Administrative Requirements ............................................ 27
2.1 Implementation of the Uniform Guidance ............................................................... 27
2.2 Original Source of Uniform Guidance Language .................................................... 29
Lesson 3: Structure of the Uniform Guidance ...................................................................... 35
3.1 Structure of the Uniform Guidance......................................................................... 35
3.1.1 Exercise: Identifying Sections in the Uniform Guidance ................................... 37
Module 2: General Provisions of the Uniform Guidance (2 CFR 200 Subparts A
and B) ............................................................................................................. 41
Lesson 1: Acronyms and Definitions in the Uniform Guidance (2 CFR 200, Subpart A) ....... 43
1.1 Acronyms (§200.0) ................................................................................................ 43
1.2 Definitions (§200.1-200.99) ................................................................................... 46
1.2.1 Essential Definitions for Grants Management................................................... 47
1.2.2 Definitions Exclusive to the Uniform Guidance ................................................. 48
Lesson 2: General Provisions of the Uniform Guidance (2 CFR 200, Subpart B) ................. 51
2.1 General Provisions ................................................................................................ 51
2.1.1 §200.100 Purpose of Subpart B ....................................................................... 51
2.1.2 §200.101 Applicability ...................................................................................... 53
2.1.3 §200.102 Exceptions........................................................................................ 60
2.1.4 §200.103 Authorities ........................................................................................ 61
© Management Concepts. See inside front cover for additional details. 3

TABLE OF CONTENTS
2.1.5 §200.104 Supersession ....................................................................................62

2.1.6 §200.105 Effect on Other Issuances .................................................................63
2.1.7 §200.106 Agency Implementation .....................................................................64
2.1.8 §200.107 OMB Responsibilities ........................................................................64
2.1.9 §200.108 Inquiries ............................................................................................64
2.1.10 §200.109 Review Date......................................................................................65
2.1.11 §200.110 Effective/Applicability Date ................................................................65
2.1.12 §200.111 English Language .............................................................................66
2.1.13 §200.112 Conflict of Interest .............................................................................67
2.1.13.1 Exercise: Reviewing a Conflict of Interest Policy.......................................72
2.1.14 §200.113 Mandatory Disclosures ......................................................................74
Module 3: Pre-Federal Award Requirements and Contents of Federal Awards (2
CFR 200 Subpart C) ....................................................................................... 79
Lesson 1: Federal Award Instruments ..................................................................................83
1.1 §200.200 Purpose of Subpart C .............................................................................83
1.2 §200.201 Use of Grant Agreements (Including Fixed Amount Awards),
Cooperative Agreements, and Contracts ................................................................84
Lesson 2: Notices of Federal Financial Assistance ...............................................................87
2.1 §200.202 Requirements to Provide Public Notice of Federal Financial
Assistance Programs .............................................................................................88
2.2 §200.203 Notices of Funding Opportunities and Appendix I to 2 CFR 200 .............91
Lesson 3: Merit Review Process.........................................................................................107
3.1 §200.204 Federal Awarding Agency Review of Merit Proposals ...........................107
Lesson 4: Pre-award Risk Assessment ..............................................................................111
4.1 §200.205 Federal Awarding Agency Review of Risk Posed by Applicants............112
Lesson 5: Application Forms ..............................................................................................117
5.1 §200.206 Standard Application Requirements ......................................................117
Lesson 6: Specific Conditions .............................................................................................119
6.1 §200.207 Specific Conditions ...............................................................................120
Lesson 7: Certifications and Representations .....................................................................123
7.1 §200.208 Certifications and Representations .......................................................123
7.2 §200.209 Pre-Award Costs ..................................................................................124
Lesson 8: Federal Award Document ...................................................................................125
8.1 §200.210 Information Contained in a Federal Award ............................................125
Lesson 9: Information that Becomes Public ........................................................................133
9.1 §200.211 Public Access to Federal Award Notification .........................................134
9.2 §200.212 Reporting a Determination That a Non-federal Entity is Not Qualified
for a Federal Award ..............................................................................................135
9.3 §200.213 Suspension and Debarment .................................................................138
4 © Management Concepts. See inside front cover for additional details.

Lesson 10: Remedies for Noncompliance ............................................................................ 139

10.1 §200.338 Remedies for Noncompliance .............................................................. 139
Module 4: Financial and Program Management Standards (2 CFR 200, Subpart
D - Subtitle I) .................................................................................................143
Lesson 1: Statutory and National Policy Requirements ...................................................... 149
1.1 §200.300 Statutory and National Policy Requirements ........................................ 149
Lesson 2: Performance Measurement ............................................................................... 157
2.1 §200.301 Performance Measurement .................................................................. 158
Lesson 3: Financial Management ...................................................................................... 161
3.1 §200.302 Financial Management ......................................................................... 161
Lesson 4: Internal Controls ................................................................................................ 165
4.1 §200.303 Internal Controls .................................................................................. 165
Lesson 5: Bonds, Payment, Cost Sharing or Matching, and Program Income ................... 169
5.1 §200.304 Bonds .................................................................................................. 169
5.2 §200.305 Payment .............................................................................................. 170
5.3 §200.306 Cost Sharing or Matching..................................................................... 176
5.4 §200.307 Program Income .................................................................................. 180
Lesson 6: Revision of Budget and Program Plans, and Period of Performance ................. 183
6.1 §200.308 Revision of Budget and Program Plans................................................ 183
6.2 §200.309 Period of Performance ......................................................................... 188
Lesson 7: Module Capstone: Reviewing a System Against the Administrative
Requirements .................................................................................................... 189
7.1 Module Capstone: Reviewing a System Against the Administrative
Requirements ...................................................................................................... 190
Module 5: Property Standards (2 CFR 200, Subpart D - Subtitle II) ...........................197
Lesson 1: Property Definitions ........................................................................................... 201
1.1 Property as Defined in the Uniform Guidance ...................................................... 201
1.1.1 Exercise: Applying Property Definitions .......................................................... 203
Lesson 2: Property Management Standards ...................................................................... 205
2.1 §200.310 Insurance Coverage............................................................................. 205
2.2 §200.311 Real Property ....................................................................................... 206
2.3 §200.312 Federally-Owned and Exempt Property ............................................... 207
2.4 §200.313 Equipment ........................................................................................... 208
2.5 §200.314 Supplies ............................................................................................... 212
2.6 §200.315 Intangible Property ............................................................................... 213
2.7 §200.316 Property Trust Relationships ................................................................ 214
2.8 Exercise: Administration of Property Types ......................................................... 216

TABLE OF CONTENTS
Module 6: Procurement Standards (2 CFR 200, Subpart D - Subtitle III) .................. 221
Lesson 1: Procurements by States .....................................................................................225
1.1 §200.317 Procurements by States .......................................................................225
Lesson 2: Procurements by Others ....................................................................................227
2.1 §200.318 General Procurement Standards ..........................................................227
2.2 §200.319 Competition ..........................................................................................231
2.3 §200.320 Methods of Procurement to be Followed ...............................................234
2.4 §200.321 Contracting with Small and Minority Businesses, Women's Business
Enterprises, and Labor Surplus Area Firms ..........................................................238
2.5 §200.322 Procurement of Recovered Materials ....................................................240
2.6 §200.323 Contract Cost and Price ........................................................................241
2.7 §200.324 Federal Awarding Agency or Pass-Through Entity Review ...................242
2.8 §200.325 Bonding Requirements .........................................................................244
Lesson 3: Contract Provisions ............................................................................................245
3.1 §200.326 Contract Provisions and Appendix II to 2 CFR 200 ...............................245
Lesson 4: Module Capstone: Revising Procurement Policies .............................................251
4.1 Module Capstone: Revising Procurement Policies ...............................................251
Module 7: Performance and Financial Monitoring and Reporting (2 CFR 200,
Subpart D - Subtitle IV) ............................................................................... 257
Lesson 1: Financial Reporting ............................................................................................261
1.1 §200.327 Financial Reporting ...............................................................................261
Lesson 2: Program Performance Reporting ........................................................................263
2.1 §200.328 Monitoring and Reporting Program Performance ..................................263
Lesson 3: Real Property Reporting .....................................................................................267
3.1 §200.329 Reporting on Real Property ..................................................................267
Module 8: Subrecipient Monitoring and Management (2 CFR 200, Subpart D -
Subtitle V)..................................................................................................... 271
Lesson 1: Subrecipient and Contractor Determinations ......................................................275
1.1 §200.330 Subrecipient and Contractor Determinations ........................................275
Lesson 2: Requirements for Pass-Through Entities ............................................................279
2.1 §200.331 Requirements for Pass-Through Entities ..............................................279
2.2 §200.332 Fixed Amount Subawards .....................................................................283
Module 9: Record Retention and Access.................................................................... 287
Lesson 1: Retention Requirements for Records .................................................................291
1.1 §200.333 Retention Requirements for Records ....................................................291
Lesson 2: Transfer and Storage Requirements for Records ...............................................295
2.1 §200.334 Requests for Transfers of Records .......................................................295
2.2 §200.335 Methods for Collection, Transmission and Storage of Information ........296

2.3 §200.336 Access to Records ............................................................................... 297

2.4 §200.337 Restrictions on Public Access to Records ............................................ 298
Module 10: Remedies for Noncompliance (2 CFR 200, Subpart D - Subtitle VII) .......303
Lesson 1: Termination Process.......................................................................................... 307
1.1 §200.339 Termination .......................................................................................... 308
1.2 §200.340 Notification of Termination Requirement .............................................. 311
1.3 §200.341 Opportunities to Object, Hearings, and Appeals ................................... 312
1.4 §200.342 Effects of Suspension and Termination ................................................ 312
Lesson 2: Module Capstone: Using the Administrative Requirements to Resolve
Termination and Enforcement Issues ................................................................ 313
2.1 Module Capstone: Using the Administrative Requirements to Resolve
Termination and Enforcement Issues .................................................................. 314
Module 11: Closeout Requirements (2 CFR 200, Subpart D - Subtitles VIII-X) ...........319
Lesson 1: Closeout Process .............................................................................................. 323
1.1 §200.343 Closeout .............................................................................................. 324
Lesson 2: Post-Closeout Requirements ............................................................................. 329
2.1 §200.344 Post-Closeout Adjustments .................................................................. 330
2.2 §200.345 Collection of Amounts Due ................................................................... 331
Module 12: Course Capstone .........................................................................................335
Lesson 1: Course Capstone: Finding Answers in the Administrative Requirements ........... 337
1.1 Course Capstone: Finding Answers in the Administrative Requirements ............. 338
Resource A: Action Plan ...............................................................................................343
Overview........................................................................................................................ 343
Part I: Key Learning Points ............................................................................................ 343
Part II: On the Job .......................................................................................................... 345
Resource B: 2 CFR 200 Crosswalk ..............................................................................351
Resource C: Agency-Specific Exceptions ...................................................................375
Agency-Specific Exceptions ........................................................................................... 375
Resource D: EPA Conflict of Interest Policy ...............................................................383
Resource E: CFDA (Assistance Listing) Notice and NOFO for Urban Indian
Health Services ........................................................................................396
Resource F: Fish & Wildlife Service Risk Assessment ..............................................421
Resource G: Sample Non-federal Entity Policies........................................................429
Resource H: Solutions ..................................................................................................439
Answers to Exercise: Administration of Property Types ................................................. 439
Suggested Solutions to Capstone: Revising Procurement Policies ................................ 440
Answers to Capstone: Using the Administrative Requirements to Resolve
Termination and Enforcement Issues .................................................................. 443

TABLE OF CONTENTS
Answers to Course Capstone: Finding Answers in the Administrative Requirements ......444

Resource I: Presentation Slides ................................................................................. 449
Bibliography.................................................................................................................... 517

Syllabus
SYLLABUS
COURSE OVERVIEW
The Office of Management and Budget’s (OMB) Uniform Guidance: Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards, (2 CFR 200) is the
cornerstone of Federal grants and financial assistance. You will learn when and how these
requirements apply to program awards throughout the grant lifecycle. This is a core course in all
tracks of the GMCP™ and is frequently scheduled with Cost Principles for Federal Grants.
Who Takes This Course

Anyone who needs to understand the fundamental rules governing Federal assistance will benefit
from this course. Participants who completed this course prior to implementation of 2 CFR 200
would benefit from retaking this course to understand the changes.
Learning Objectives
 Describe the history, purpose, and applicability of the Uniform Administrative Requirements
 Use 2 CFR 200, Subparts A & B, to locate information about general terms and requirements
 Identify the pre-award requirements for federal awarding agencies and describe how they
affect non-federal entities
 Use 2 CFR 200, Subpart D, to locate needed information about financial and program
management standards
 Use 2 CFR 200, Subpart D, to locate needed information about property requirements
 Use 2 CFR 200, Subpart D, to locate needed information about procurement requirements
 Use 2 CFR 200, Subpart D, to locate needed information about reporting requirements
 Use 2 CFR 200, Subpart D, to locate needed information about subawards
 Use 2 CFR 200, Subpart D, to locate information about award records
 Use 2 CFR 200, Subpart D, to locate needed information about noncompliance and
termination

SYLLABUS
 Use 2 CFR 200, Subpart D, to locate needed information about closeout
 Apply the administrative requirements found in the Uniform Guidance
Prerequisites
Suggested
 Monitoring Federal Grants and Cooperative Agreements for Federal Personnel
 Managing Federal Grants and Cooperative Agreements for Recipients
 Cost Principles for Federal Grants: 2 CFR Part 200 (Subpart E) and FAR 31.2
 Performance Measurement for Federal Grants Under 2 CFR 200
 Subawarding for Pass-Through Entities
COURSE EXPECTATIONS
Required Texts
The following required materials will be issued to each participant and will be used throughout the
course.
Management Concepts®, Uniform Administrative Requirements for Federal Grants © [Includes text,
appendices, and handouts.]
Course Delivery Guide Icons

The following icons are used throughout the Course Delivery Guide to support delivery across
training modalities.
COURSE DELIVERY GUIDE ICON KEY
Course Delivery Note
Discussion
Example
Present Media

Refer to Resource
Refer to Website
Show Slide
Tip
Course Schedule
Day One
Morning Introductions and Course Administration
Module 1: Introduction to the Uniform Administrative Requirements
Module 2: General Provisions of the Uniform Guidance (2 CFR 200 Subparts A

and B)
Module 3: Pre-Federal Award Requirements and Contents of Federal Awards (2

CFR 200 Subpart C)
Lunch
Afternoon Module 3: Pre-Federal Award Requirements and Contents of Federal Awards (2

CFR 200 Subpart C) (continued)
Module 4: Financial and Program Management Standards (2 CFR 200, Subpart

D - Subtitle I)
Module 5: Property Standards (2 CFR 200, Subpart D - Subtitle II)
Day Two
Morning Module 5: Property Standards (2 CFR 200, Subpart D - Subtitle II) (continued)

SYLLABUS
Day Two
Module 6: Procurement Standards (2 CFR 200, Subpart D - Subtitle III)
Module 7: Performance and Financial Monitoring and Reporting (2 CFR 200,

Subpart D - Subtitle IV)
Module 8: Subrecipient Monitoring and Management (2 CFR 200, Subpart D -

Subtitle V)
Module 9: Record Retention and Access
Module 10: Remedies for Noncompliance (2 CFR 200, Subpart D - Subtitle VII)
Lunch
Afternoon Module 10: Remedies for Noncompliance (2 CFR 200, Subpart D - Subtitle VII)
(continued)
Module 11: Closeout Requirements (2 CFR 200, Subpart D - Subtitles VIII-X)
Module 12: Course Capstone: Finding Answers in the Administrative

Requirements
Exam
Requirements for Successful Completion

Attendance and Participation
Full (100%) attendance is expected and required. Successful completion of the course depends on
full class attendance and active participation in individual and group exercises.
Graded Activities
The final exam must be completed with a grade of 70% or higher.
PROFESSIONAL BENEFITS
Many Management Concepts courses are designed to meet the standards and requirements of
leading industry organizations. Participants seeking information regarding earned credentials or
recognition, such as college and continuing education credit and professional certification, should
refer to the certificate of completion issued at the end of the course.

Refer to Website
For additional information about credits and certifications

available for Management Concepts courses, please visit:
http://managementconcepts.com/Credits-Certifications

SYLLABUS

Introduction to the Uniform
Administrative
Requirements
MODULE 1 | INTRODUCTION TO THE UNIFORM ADMINISTRATIVE REQUIREMENTS
INTRODUCTION TO THE UNIFORM

ADMINISTRATIVE REQUIREMENTS
Module Objective
 Describe the history, purpose, and applicability of the Uniform Administrative Requirements
Lessons
1. Significance and Applicability of the Uniform Administrative Requirements
2. History of the Uniform Administrative Requirements
3. Structure of the Uniform Guidance


LESSON 1
SIGNIFICANCE AND APPLICABILITY OF
THE UNIFORM ADMINISTRATIVE
REQUIREMENTS
Lesson Objective
After completing this lesson, you should be able to:
 Explain the significance of the Uniform Administrative Requirements for grants management
and its applicability to your awards
1.1 SIGNIFICANCE OF THE UNIFORM ADMINISTRATIVE

REQUIREMENTS
eCFR website screen capture, showing opening page for eCFR for Part 200, Uniform Administrative Requirements for Federal Awards.
The Uniform Guidance: Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards (Uniform Guidance) is found in 2 CFR 200 and sometimes

LESSON 1 | SIGNIFICANCE AND APPLICABILITY OF THE UNIFORM ADMINISTRATIVE
REQUIREMENTS
referred to as the "Supercircular" or "OmniCircular." It is the culmination of years of collaboration

between federal agencies, recipients, and other stakeholders in the grants community.
The Office of Management and Budget (OMB) and the Council on Financial Assistance Reform
(COFAR) developed the Uniform Guidance with the purpose of reducing administrative burdens,
streamlining requirements for federal awards, and protecting federal funds from waste, fraud, and
abuse. 2 CFR 200 consolidates eight grants-related guidance into a single set of requirements,
thereby creating uniform requirements for all recipient entities (with only minor exceptions) to follow
and all federal agencies to monitor.
Tip
On June 15, 2017, through Memorandum M-17-26, the Office of

Management and Budget (OMB) disbanded the Council on
Financial Assistance Reform (COFAR).
The term "uniform administrative requirements" refers to the provisions within the Uniform Guidance
that relate to the pre-award, post-award, and closeout phases of the grants life cycle, located in
Subparts C and D. Specifically, the uniform administrative requirements establish the requirements
for financial management systems, procurement, reports and records, and grant closeouts for non-
federal entities. The uniform administrative requirements also explain the responsibilities of federal
awarding agencies and pass-through entities in awarding, monitoring, and closing out of grant
awards.

Grants Life Cycle: Pre-Award, Post-Award, and Closeout Phases

REQUIREMENTS
Discussion
 Poll: Do you believe the Uniform Guidance consistently
applies to all award recipients?
A Yes
B No
 Who are some of the entities impacted by the Uniform

Guidance reform?
 What are some of the primary advantages to creating
uniform requirements for all recipient entities?
 To what phases of the grants life cycle do the provisions in 2
CFR 200 refer?
 In what specific areas does the Uniform Guidance establish
requirements?
 What else does the Uniform Guidance address besides
these requirements?
1.2 THE IMPORTANCE OF COMPLIANCE

Compliance with the Uniform Guidance, or the awarding agency’s implementation of those
requirements, is a condition of receiving federal grant funds. Agencies may impose sanctions on a
recipient that fails to comply with the terms and conditions of an award. Sections 200.338 through
200.342 identify consequences of recipient noncompliance.
Disallowances are often associated with a recipient’s failure to follow the applicable cost principles.
However, failure to follow the administrative requirements can also result in a disallowance by the
awarding agency.

Example: Sample Disallowance for Failure to Follow

Administrative Requirements
National Health Plan, Inc. (NHP), a nonprofit organization,

operated two community health centers funded in part by a
Health Resources and Services Administration (HRSA) grant.
NHP solicited bids for an audit of its operations, and awarded
the contract to an auditor located in another city who knew the
chairman of NHP: his bid was $33,000. Two local audit firms
submitted bids of $15,000 and $16,500, respectively. The HHS’
Office of the Inspector General, Office of Audit, recommended
that HRSA disallow the difference between the successful bid
and the higher of the two unsuccessful bids ($16,500), and the
recipient appealed. The HHS Departmental Appeals Board
(DAB) upheld the disallowance, based on the requirements of
the applicable administrative requirements relating to
procurement transactions, particularly the language requiring
open and free competition, and the requirement that price be
considered, among other factors, when selecting the successful
bidder. NHP’s request for a remand of the matter to HRSA was
denied, in part because of the recipient’s failure to produce a
copy of the successful bid or the resulting contract, although
copies of the unsuccessful bids were produced. (DAB Decision
no. 871.) 1
Activity: Consequences for Uniform Guidance Incompliance
Compliance to the Uniform Guidance is very important, as there

can be serious consequences for businesses that do not comply.
What do you think some of these consequences might be?
1. Partner with a classmate and take five minutes to look up
these consequences.
2. Hint: You can find this information in Section 200.338 of
eCFR 200, which can be accessed online at
http://www.ecfr.gov, or within the Remedies for
Noncompliance lesson of this course.
1.3 "SHOULD" VERSUS "MUST"

The Uniform Guidance uses the words "should" and "must" when identifying the responsibilities of
federal awarding agencies and non-federal entities. It is important to understand the meaning of
each word.
The word "should" implies a suggested course of action and generally refers to best practices. The
word "must" indicates a required action. Failure to comply with a required action may result in an
1
U.S. Department of Health and Human Services Departmental Grant Appeals Board, National Health Plan, Inc., DAB No.
871 (1987), <https://www.hhs.gov/sites/default/files/static/dab/decisions/board-decisions/1987/dab871.html>

REQUIREMENTS
audit finding, the federal awarding agency or pass-through entity imposing special conditions on the
award, and/or legal consequences.

LESSON 2
HISTORY OF THE UNIFORM
Lesson Objective
After completing this lesson, you will be able to:
 Understand the history behind the Uniform Guidance
2.1 IMPLEMENTATION OF THE UNIFORM GUIDANCE
Timeline of the Uniform Guidance Implementation
On December 19, 2014, OMB and 26 federal awarding agencies published a joint interim final rule
implementing 2 CFR 200. The interim rule contained each agency's implementing regulations for 2
CFR 200 and modifications to 2 CFR 25 Universal Identifier and System of Award Management, 2
CFR 170 Reporting Subaward and Executive Compensation Information, and 2 CFR 180 OMB
Guidelines to Agencies on Government Debarment and Suspension (Nonprocurement). The

LESSON 2 | HISTORY OF THE UNIFORM ADMINISTRATIVE REQUIREMENTS
modifications to 2 CFR 25, 2 CFR 170, and 2 CFR 180 were designed to align each policy with 2
CFR 200.
Subsequently, on July 22, 2015, OMB published modifications to 2 CFR 180 and 200 to incorporate
requirements related to the Federal Award Performance Integrity and Information System (FAPIIS),
which had previously been proposed as 2 CFR Subparts 27, 35, and 77. Most federal awarding
agencies have now adopted final rules to implement the Uniform Guidance and any agency-specific
exceptions.
The administrative requirements and cost principles found in the Uniform Guidance are applicable
to all new awards issued on or after December 26, 2014. Awards issued prior to that date will
continue to follow the existing terms and conditions of the award. Federal awarding agencies may
apply 2 CFR 200 to older awards if new terms and conditions are issued along with additional
funding (funding increments). The audit requirements in 2 CFR 200 will apply to a non-federal entity
during the entity's first full fiscal year after the implementation date of December 26, 2014.
OMB Circulars Combined into the Uniform Guidance, 2 CFR 200
The following table identifies the grants-related guidance that were consolidated into the Uniform
Guidance.
Subject Guidance Entity
Cost Principles 2 CFR 225 State, Local, and Indian

(OMB Circular A-87) Tribal Governments

Subject Guidance Entity
2 CFR 220 Institutions of Higher

(OMB Circular A-21) Education
2 CFR 230 Nonprofit Organizations

(OMB Circular A-122)
Administrative Requirements 2 CFR 215 Educational Institutions,

(OMB Circular A-110) Hospitals, and Nonprofits
OMB Circular A-102 State and Local

Governments
Audits OMB Circular A-133 State and Local

Governments, Educational
Institutions, and Nonprofits
OMB Circular A-50 Federal
Assistance Listings OMB Circular A-89 Federal
In addition to consolidating grants guidance, the Uniform Guidance alters grants administration by
implementing new, and modifying previous, requirements.
Refer to Website
2 CFR 200 can also be accessed at https://www.ecfr.gov.
Discussion
What are your biggest concerns about the uniform administrative

requirements?
2.2 ORIGINAL SOURCE OF UNIFORM GUIDANCE LANGUAGE

OMB consolidated A-102 and 2 CFR 215 into Subparts C and D of the Uniform Guidance. A-102
and 2 CFR 215 generally addressed the same topics; however, the two documents frequently used
different language and often differed in the amount of detail and requirements. In crafting the
Uniform Guidance, OMB generally adopted the language found in either A-102 or 2 CFR 215. In
some occasions, OMB used language found in both circulars, and in other situations, OMB created
new provisions that were not previously in either A-102 or 2 CFR 215.
The following table identifies the predominant source of language for each section in Subpart C.

Section Source of Language
200.200 Purpose Combined from all
200.201 Use of Grants, Cooperative Agreements, and Contracts 2 CFR 215
200.202 Requirement to Provide Public Notice of Federal Financial Assistance A-89

Programs
200.203 Announcement of Funding Opportunities 68 FR 37376-37378
200.204 Federal Awarding Agency Review of Merit of Proposals NEW
200.205 Federal Awarding Agency Review of Risk Posed by Applicants NEW
200.206 Standard Application Requirements NEW
200.207 Specific Conditions 2 CFR 215
200.208 Certifications and Representations 2 CFR 215
200.209 Pre-Award Costs NEW
200.210 Information Contained in Federal Awards NEW
200.211 Public Access to Federal Award Information NEW
200.212 Reporting a Determination that a Non-Federal Entity is Not Qualified for a NEW
Federal Award
200.213 Suspension and Debarment NEW
The following table identifies the predominant source of language used for each section in Subpart
D.
Section Source of
Language
200.300 Statutory and National Policy Requirements A-102 & 2 CFR 215
(A-110)
200.301 Performance Measures 2 CFR 215 (A-110)
200.302 Financial Management 2 CFR 215 (A-110)
200.303 Internal Control A-133

Section Source of
Language
200.304 Bonds 2 CFR 215 (A-110)
200.305 Payment 2 CFR 215 (A-110)
200.306 Cost Sharing or Matching 2 CFR 215 (A-110)
200.307 Program Income A-102 & 2 CFR 215

(A-110)
200.308 Revisions of Budget and Program Plans 2 CFR 215 (A-110)
200.309 Period of Performance 2 CFR 215 (A-110)
200.310 Insurance Coverage 2 CFR 215 (A-110)
200.311 Real Property A-102
200.312 Federally-Owned and Exempt Property 2 CFR 215 (A-110)
200.313 Equipment A-102
200.314 Supplies 2 CFR 215 (A-110)
200.315 Intangible Property 2 CFR 215 (A-110)
200.316 Property Trust Relationship 2 CFR 215 (A-110)
200.317 Procurements by States A-102
200.318 General Procurement Standards 2 CFR 215 (A-110)
200.319 Competition A-102
200.320 Methods of Procurement to be Followed A-102
200.321 Contracting with Small and Minority Businesses, Women's Business A-102
Enterprises, and Labor Surplus Area Firms
200.322 Procurement of Recovered Materials A-102
200.323 Contract Cost and Price A-102
200.324 Federal Awarding Agency or Pass-Through Entity Review A-102
200.325 Bonding Requirements A-102

Section Source of
Language
200.326 Contract Provisions A-102
200.327 Financial Reporting A-102
200.328 Monitoring and Reporting Program Performance A-102
200.329 Reporting on Real Property A-102
200.330 Subrecipient and Contractor Determinations A-133
200.331 Requirements for Pass-through Entities A-133
200.332 Fixed Amount Subawards NEW
200.333 Record Retention and Access A-102
200.334 Requests for Transfers of Records A-102
200.335 Methods for Collection, Transmission, and Storage of Information A-102
200.336 Access to Records A-102
200.337 Restrictions on Public Access to Records A-102
200.338 Remedies for Noncompliance 2 CFR 215 (A-110)
200.339 Termination 2 CFR 215 (A-110)
200.340 Notification of termination requirement 2 CFR 215 (A-110)
200.341 Opportunities to Object, Hearings, and Appeals 2 CFR 215 (A-110)
200.342 Effects of Suspension and Termination 2 CFR 215 (A-110)
200.343 Closeout 2 CFR 215 (A-110)
200.344 Post-Closeout Adjustments and Continuing Responsibilities 2 CFR 215 (A-110)
200.345 Collection of Amounts Due A-102
The following table identifies which sections from the previous administrative requirements were
used for the Uniform Guidance.

A-102 (Grants and Cooperative Agreements 2 CFR 215 (Uniform Administrative

with State and Local Governments) Requirements for Institutions of Higher
Education, Hospitals, and Other Non-Profit
Organizations)
200.311 Real Property 200.301 Performance Measures
200.313 Equipment 200.302 Financial Management
200.317 Procurements by States 200.304 Bonds
200.319 Competition 200.305 Payment
200.320 Methods of Procurement to be Followed 200.306 Cost Sharing or Matching
200.321 Contracting with Small and Minority 200.308 Revisions of Budget and Program Plans
Businesses, Women's Business Enterprises, and
Labor Surplus Area Firms
200.322 Procurement of Recovered Materials 200.309 Period of Performance
200.323 Contract Cost and Price 200.310 Insurance Coverage
200.324 Federal Awarding Agency or Pass-Through 200.312 Federally-Owned and Exempt Property
Entity Review
200.325 Bonding Requirements 200.314 Supplies
200.326 Contract Provisions 200.315 Intangible Property
200.327 Financial Reporting 200.316 Property Trust Relationship
200.328 Monitoring and Reporting Program 200.318 General Procurement Standards

Performance
200.329 Reporting on Real Property 200.338 Remedies for Noncompliance
200.333 Record Retention and Access 200.339 Termination
200.334 Requests for Transfers of Records 200.340 Notification of termination requirement
200.335 Methods for Collection, Transmission, and 200.341 Opportunities to Object, Hearings, and
Storage of Information Appeals
200.336 Access to Records 200.342 Effects of Suspension and Termination
200.337 Restrictions on Public Access to Records 200.343 Closeout

A-102 (Grants and Cooperative Agreements 2 CFR 215 (Uniform Administrative

with State and Local Governments) Requirements for Institutions of Higher
Education, Hospitals, and Other Non-Profit
Organizations)
200.345 Collection of Amounts Due 200.344 Post-Closeout Adjustments and Continuing

Responsibilities
Subpart D contains new provisions and modifications to previous administrative requirements,

including:
 Requiring recipients to provide information to the awarding entity demonstrating cost effective
practices, such as unit cost data (2 CFR 200.301)
 Explicitly stating that the recipient's responsibilities in implementing and maintaining effective
internal controls include safeguarding of personally identifiable information on all documents (2
CFR 200.303)
 Increasing the interest accountability threshold to $500 for all non-federal entities (2 CFR
200.305)
 Clarifying when voluntarily committed cost sharing for research awards cannot be a factor in the
awarding process or calculated into the indirect (F&A) cost rate (2 CFR 200.306)
 Tying the simplified acquisition threshold to the FAR (2 CFR 200.318)
 Prohibiting recipients from giving geographical preference in awarding contracts under a grant
award (2 CFR 200.319)
 Encouraging the electronic submission of all grants-related documents to comply with Executive
Order 13642, Making Open and Machine Readable the New Default of Government Information
(2 CFR 200.335)
 Clearly identifying tools for agencies and pass-through entities to use for non-compliant
recipients and subrecipients (2 CFR 200.338)
 Recommending agencies and pass-through entities to close out all awards within one year after
receipt and acceptance the final documents (2 CFR 200.343)
 Mandating that agencies notify recipients when terminating awards (2 CFR 200.340)
 Prohibiting the awarding agency or pass-through entity from disallowing costs after the three-
year record retention period has expired (2 CFR 200.344)

LESSON 3
STRUCTURE OF THE UNIFORM
GUIDANCE
Lesson Objective
 Locate information within the Uniform Guidance
3.1 STRUCTURE OF THE UNIFORM GUIDANCE
Structure of 2 CFR 200
The Uniform Guidance contains six subparts and twelve appendices. The subparts are arranged to
correspond with the grants life cycle.
The Uniform Guidance is composed of:
 Subpart A - Acronyms and Definitions (2 CFR 200.0 to 2 CFR 200.99)
 Subpart B - General Provisions (2 CFR 200.100 to 2 CFR 200.113)
 Subpart C - Pre-Federal Award Requirements and Contents of Federal Awards (2 CFR 200.200
to 2 CFR 200.213)
 Subpart D - Post-Federal Award Requirements (2 CFR 200.300 to 2 CFR 200.345)
 Subpart E - Cost Principles (2 CFR 200.400 to 2 CFR 200.475)
 Subpart F - Audit Requirements (2 CFR 200.500 to 2 CFR 200.521)
 Appendices (Appendix I to Appendix XII)
Management Concepts has developed a crosswalk for the Uniform Guidance. For each section of
the Uniform Guidance, the crosswalk provides a summary of the section, identifies the predominant
source of language used for the section, and indicates any significant change to policy.

LESSON 3 | STRUCTURE OF THE UNIFORM GUIDANCE
Refer to Website
The Uniform Guidance is available at http://www.ecfr.gov

3.1.1 EXERCISE: IDENTIFYING SECTIONS IN THE UNIFORM

GUIDANCE
Overview
Use the Uniform Guidance to find relevant sections.

Directions
1. Read each of the scenarios below.
2. Use 2 CFR 200 in the text, at your table, or at https://www.ecfr.gov to identify the section in
the Uniform Guidance that would help you resolve each scenario.
Scenarios
1. Your boss wants to know how frequently your entity must submit financial reports.
2. You believe the Department of Education wrongly terminated your grant award and you want to
know your available options.
3. Your project generated $5,000 in program income and you need to know how to handle these
funds.
4. You just purchased $14,300 worth of computer equipment and you need to determine your
entity's responsibilities for keeping property records.
5. You are assigned with developing a pre-award risk assessment framework for your agency's
grant competition. What section in the Uniform Guidance would provide guidance in this task?
6. Your project ends in one week and you need to determine your responsibilities once funding
ends.

Action Planning
Refer to the Action Plan and record ideas to implement from this
module.

General Provisions of the
Uniform Guidance (2 CFR
200 Subparts A and B)
MODULE 2 | GENERAL PROVISIONS OF THE UNIFORM GUIDANCE (2 CFR 200 SUBPARTS A AND B)
GENERAL PROVISIONS OF THE

UNIFORM GUIDANCE (2 CFR 200
SUBPARTS A AND B)
Module Objective
 Use 2 CFR 200, Subparts A & B, to locate information about general terms and
requirements
Lessons
1. Acronyms and Definitions in the Uniform Guidance (2 CFR 200, Subpart A)
2. General Provisions of the Uniform Guidance (2 CFR 200, Subpart B)


LESSON 1
ACRONYMS AND DEFINITIONS IN THE
UNIFORM GUIDANCE (2 CFR 200,
SUBPART A)
Lesson Objective
2.1.1 Identify and define acronyms and terms used in the Uniform Guidance
1.1 ACRONYMS (§200.0)

Subpart A of 2 CFR 200 identifies commonly used acronyms used throughout the Uniform
Guidance and provides definitions to important terms in grants administration. Understanding and
accurately applying the terms and definitions is critical in managing federal awards.
The following lists some of the key acronyms found at 2 CFR 200.0:
Acronym Term Acronym Term

A-E F
CAS Cost Accounting Standards F&A Facilities and Administration
CFR Code of Federal Regulations FAIN Federal Award Identification

Number
CMIA Cash Management FAPIIS Federal Awardee

Improvement Act Performance and Integrity
Information System
COG Councils Of Governments FAR Federal Acquisition

Regulation
COSO Committee of Sponsoring FFATA Federal Funding

Organizations of the Accountability and
Treadway Commission Transparency Act of 2006
EPA Environmental Protection FICA Federal Insurance

Agency Contributions Act

LESSON 1 | ACRONYMS AND DEFINITIONS IN THE UNIFORM GUIDANCE (2 CFR 200, SUBPART A)

A-E F
ERISA Employee Retirement FOIA Freedom of Information Act

Income Security Act of 1974
EUI Energy Usage Index FR Federal Register
FTE Full-time equivalent
Table: 2 CFR 200 Acronyms—A-E and F Terms

G-I M-R
GAAP Generally Accepted MTC Modified Total Cost

Accounting Principles
GAGAS Generally Accepted MTDC Modified Total Direct

Government Auditing Cost
Standards
GAO Government NFE Non-Federal Entity

Accountability Office
GOCO Government Owned, OMB Office of Management

Contractor Operated and Budget
GSA General Services PII Personally Identifiable

Administration Information
IBS Institutional Base Salary PMS Payment Management

System
IHE Institutions of Higher PRHP Post-retirement Health

Education Plans
IRC Internal Revenue Code PTE Pass-through Entity


G-I M-R
ISDEAA Indian Self-Determination REUI Relative Energy Usage

and Education and Index
Assistance Act
Table: 2 CFR 200 Acronyms—G-I and M-R Terms

S T-V
SAM System for Award TANF Temporary Assistance

Management (accessible for Needy Families
at https://www.sam.gov)
SFA Student Financial Aid TFM Treasury Financial

Manual
SNAP Supplemental Nutrition U.S.C. United States Code

Assistance Program
SPOC Single Point of Contact VAT Value Added Tax
Table: 2 CFR 200 Acronyms—S and T-Z Terms
The following list identifies and explains some of the key acronyms in the Uniform Guidance.
 Assistance Listings (Formerly known as Catalog of Federal Domestic Assistance
(CFDA)). The single, authoritative, governmentwide source document of all federal financial
assistance programs to non-federal entities.
 Code of Federal Regulations (CFR). The codification of the general and permanent rules and
regulations published in the Federal Register. The Uniform Guidance is located in Title 2.
 Committee of Sponsoring Organizations of the Treadway Commission (COSO). This
association is a joint initiative of five private sector organizations, including the American
Institute of CPAs and the American Accounting Association, that has developed a framework for
internal controls. The Uniform Guidance suggests non-federal entities use the framework in
developing their internal controls.
 Indirect (facilities & administrative (F&A)) costs. Those costs incurred for a common or joint
purpose benefitting more than one cost objective, and not readily assignable to the cost
objectives specifically benefitted, without effort disproportionate to the results achieved.
 Federal Acquisition Regulation (FAR). Establishes the rules and regulations for awarding
contracts, sets the micro-purchase threshold and the Simplified Acquisition Threshold, and
aligns the threshold for colleges and universities to comply with Cost Accounting Standards.

 Federal Audit Clearing House (FAC). The federal repository of record which non-federal
entities are required to transmit single audit reporting packages.
 Federal Award Identification Number (FAIN). A unique number assigned to each federal
award by an awarding agency. This number must be used on all award documents. Pass-
through entities are required to inform subrecipients of this number and associated
requirements of use.
Refer to Website
OMB released a memo detailing how federal awarding agencies and non-federal
entities should use the FAIN.The OMB memo is available at:
https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/financial/memo
s/improving-data-quality-for-usaspending-gov.pdf
 Institutions of Higher Education (IHEs). Term referring to colleges and universities.

 Modified Total Direct Cost (MTDC). Means all direct salaries and wages, applicable fringe
benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward
(regardless of the period of performance of the subawards under the award). MTDC excludes
equipment, capital expenditures, charges for patient care, rental costs, tuition remission,
scholarships and fellowships, participant support costs and the portion of each subaward in
excess of $25,000. Other items may only be excluded when necessary to avoid a serious
inequity in the distribution of indirect costs, and with the approval of the cognizant agency for
indirect costs.
 Office of Management and Budget (OMB).- Federal agency within the Executive Office of the
President that issues, among other documents, grants-related guidance for federal agencies.
 Pass-through Entity (PTE). A non-federal entity that provides subawards to another non-
federal entity to carry out a part of a federal award.
 Personally Identifiable Information (PII). Refers to items that can be used to distinguish or
trace an individual's identity, such as first and last name, address, e-mail address, telephone
numbers, or Social Security Number. The Uniform Guidance requires non-federal entities to
safeguard this information as part of the entity's internal controls.
 System for Award Management (SAM). Non-federal entities must register with this
government website before applying for a federal grant. The website also contains the
Exclusions Extract that identifies the individuals and entities that have been suspended or
debarred from receiving a grant or contract.
Discussion
Which acronyms are new to you?
1.2 DEFINITIONS (§200.1-200.99)

Subpart A also contains the definitions for terms used in the Uniform Guidance. While many of the
terms may seem intuitive, it is critical for individuals involved in grants management to have a
working knowledge and understanding of how the terms apply to federal awards.

2 CFR 200.1 serves as the introduction to the definitions section. This section notes that the
provided definitions are only applicable to the Uniform Guidance. Federal statutes, program
regulations, and some governmentwide information collection forms may use alternative language.
2 CFR 200.2 through 2 CFR 200.99 provide definitions for key grants-related terms. The terms are
listed in alphabetical order. Each section identifies a term and provides the definition for the term.
For example, the definition for acquisition cost, found at 2 CFR 200.02, reads:
Acquisition cost means the cost of the asset including the cost to ready the asset for
its intended use. Acquisition cost for equipment, for example, means the net invoice
price of the equipment, including the cost of any modifications, attachments,
accessories, or auxiliary apparatus necessary to make it usable for the purpose for
which it is acquired. Acquisition costs for software includes those development costs
capitalized in accordance with generally accepted accounting principles (GAAP).
Ancillary charges, such as taxes, duty, protective in transit insurance, freight, and
installation may be included in or excluded from the acquisition cost in accordance
with the non-Federal entity’s regular accounting practices.
1.2.1 Essential Definitions for Grants Management

The definitions used in the Uniform Guidance are taken from previous grant circulars, are modified
from the previous grant circulars, or are exclusive to the Uniform Guidance. One of the most
significant changes to grants terminology is the use of the term "non-federal entity," found at 2 CFR
200.69. The Uniform Guidance uses this term to refer to any recipient or subrecipient of federal
grant awards. "Non-federal entity" is used in lieu of recipient, grantee, subrecipient, and subgrantee.
Understanding the term "federal award" is also essential to comprehending the Uniform Guidance
(2 CFR 200.38). The Uniform Guidance uses the term "federal award" to refer to the federal
financial assistance that a federal awarding agency provides to a non-federal entity and to the
documentation establishing the terms and conditions for a non-federal entity's acceptance of
funding.
The following are additional terms found in the Uniform Guidance that serve as the foundation for
federal grants management:
 Contract (§200.22)
 Cooperative agreement (§200.24)
 Federal awarding agency (§200.37)
 Grant agreement (§200.51)
 Indian tribe (§200.54)
 Institutions of higher education (IHEs) (§200.55)
 Pass-through entity (§200.74)
 State (§200.90)
 Subaward (§200.92)
 Subrecipient (§200.93)
It is important to note that the Uniform Guidance defines Indian tribes as a separate entity from
state governments. In previous guidance, Indian tribes were classified as a subset of state
governments. This change will not affect the ability of Indian tribes to apply for grants reserved for
state and local governments, as the definition is only applicable to the Uniform Guidance.

In technical corrections to 2 CFR 200, OMB removed the definition for the Data Universal
Numbering System (DUNS), which was previously found at 2 CFR 200.32. Instead of DUNS, OMB
now references the "unique entity number." 2 CFR 200 now states that an entity's DUNS Number
will serve as the unique entity number until further notice. Additionally, the Dun and Bradstreet
(D&B) acronym was removed from the Uniform Guidance.
1.2.2 Definitions Exclusive to the Uniform Guidance
Word Cloud Showing Terms Exclusive to the Uniform Guidance
The Uniform Guidance contains 42 definitions that were not previously included in any grants-
related guidance: 2 CFR 215, A-102, A-21, A-122, A-87, or A-133. The following list identifies the
definitions exclusive to the Uniform Guidance:
 Budget (§200.8)
 Capital assets (§200.12)
 Capital expenditures (§200.13)
 Assistance Listings (Formerly known as CFDA) program title (§200.11)
 Class of federal awards (§200.15)
 Closeout (§200.16)
 Cluster of programs (§200.17)
 Cognizant agency for indirect cost (§200.19)
 Ccomputing devices (§200.20)
 Contractor (§200.23)
 Cooperative audit resolution (§200.25)
 Cross-cutting audit finding (§200.30)
 Federal Audit Clearinghouse (FAC) (§200.36)
 Federal award date (§200.39)
 Fixed amount awards (§200.45)
 Foreign organization (§200.47)
 Foreign public entity (§200.46)
 General purpose equipment (§200.48)

 Generally Accepted Accounting Principles (GAAP) (§200.49)

 Generally Accepted Government Auditing Standards (GAGAS) (§200.50)
 Hospital (§200.52)
 Improper payment (§200.53)
 Information technology systems (§200.58)
 Institution of higher education (IHE) (§200.55)
 Intangible property (§200.59)
 Internal control pertaining to the compliance requirements for federal awards (§200.62)
 Internal controls (§200.61)
 Micro-purchase (§200.67)
 Modified total direct cost (MTDC) (§200.68)
 Participant support costs (§200.75)
 Performance goals (§200.76)
 Period of performance (§200.77)
 Personal property (§200.78)
 Personally identifiable information (PII) (§200.79)
 Program income (§200.80)
 Project cost (§200.83)
 Protected personally identifiable information (Protected PII) (§200.82)
 Real property (§200.85)
 Simplified acquisition threshold (§200.88)
 Special purpose equipment (§200.89)
 Voluntary committed cost sharing (§200.99)
Discussion
 Of the new definitions, which is most useful?

 Do any leave room for further questions?


LESSON 2
GENERAL PROVISIONS OF THE
UNIFORM GUIDANCE (2 CFR 200,
SUBPART B)
Lesson Objective
2.2.1 Explain the general provisions of the Uniform Guidance
2.1 GENERAL PROVISIONS

2 CFR 200 Subpart B contains General Provisions. This Subpart identifies the purposes of the
Uniform Guidance, details the applicability to federal financial assistance awards, and includes key
requirements for federal awarding agencies and non-federal entities.
2.1.1 §200.100 Purpose of Subpart B

2 CFR 200.100 explains the purpose of the Uniform Guidance as an attempt to standardize existing
grant requirements into a single document. 2 CFR 200 limits the ability of federal awarding
agencies from imposing additional or inconsistent requirements on non-federal entities. This section
also explains the purpose of each subpart of 2 CFR 200.

LESSON 2 | GENERAL PROVISIONS OF THE UNIFORM GUIDANCE (2 CFR 200, SUBPART B)
§200.100 Purpose.
(a)(1) This part establishes uniform administrative requirements,

cost principles, and audit requirements for Federal awards to
non-Federal entities, as described in §200.101 Applicability.
Federal awarding agencies must not impose additional or
inconsistent requirements, except as provided in §§200.102
Exceptions and 200.210 Information contained in a Federal
award, or unless specifically required by Federal statute,
regulation, or Executive Order.
(2) This part provides the basis for a systematic and periodic
collection and uniform submission by Federal agencies of
information on all Federal financial assistance programs to the
Office of Management and Budget (OMB). It also establishes
Federal policies related to the delivery of this information to the
public, including through the use of electronic media. It
prescribes the manner in which General Services Administration
(GSA), OMB, and Federal agencies that administer Federal
financial assistance programs are to carry out their statutory
responsibilities under the Federal Program Information Act (31
U.S.C. 6101-6106).
(b) Administrative requirements. Subparts B through D of this

part set forth the uniform administrative requirements for grant
and cooperative agreements, including the requirements for
Federal awarding agency management of Federal grant
programs before the Federal award has been made, and the
requirements Federal awarding agencies may impose on non-
Federal entities in the Federal award.
(c) Cost Principles. Subpart E—Cost Principles of this part

establishes principles for determining the allowable costs
incurred by non-Federal entities under Federal awards. The
principles are for the purpose of cost determination and are not
intended to identify the circumstances or dictate the extent of
Federal government participation in the financing of a particular
program or project. The principles are designed to provide that
Federal awards bear their fair share of cost recognized under
these principles except where restricted or prohibited by statute.
(d) Single Audit Requirements and Audit Follow-up. Subpart F—

Audit Requirements of this part is issued pursuant to the Single
Audit Act Amendments of 1996, (31 U.S.C. 7501-7507). It sets
forth standards for obtaining consistency and uniformity among
Federal agencies for the audit of non-Federal entities expending
Federal awards. These provisions also provide the policies and
procedures for Federal awarding agencies and pass-through
entities when using the results of these audits.
(e) For OMB guidance to Federal awarding agencies on

Challenges and Prizes, please see M-10-11 Guidance on the
Use of Challenges and Prizes to Promote Open Government,

issued March 8, 2010, or its successor.
2.1.2 §200.101 Applicability

2 CFR 200.101 outlines the applicability of the Uniform Guidance to assistance awards. As
explained at 2 CFR 200.101(b), the terms and conditions of federal awards flow down to subawards
and subrecipients, unless the award terms and conditions state otherwise.
§200.101 Applicability.
(a) General applicability to Federal agencies. The requirements

established in this part apply to Federal agencies that make
Federal awards to non-Federal entities. These requirements are
applicable to all costs related to Federal awards.
(b)(1) Applicability to different types of Federal awards. The

following table describes what portions of this part apply to
which types of Federal awards. The terms and conditions of
Federal awards (including this part) flow down to subawards to
subrecipients unless a particular section of this part or the terms
and conditions of the Federal award specifically indicate
otherwise. This means that non-Federal entities must comply
with requirements in this part regardless of whether the non-
Federal entity is a recipient or subrecipient of a Federal award.
Pass-through entities must comply with the requirements
described in Subpart D—Post Federal Award Requirements of
this part, §§200.330 Subrecipient and contractor determinations
through 200.332 Fixed amount Subawards, but not any
requirements in this part directed towards Federal awarding
agencies unless the requirements of this part or the terms and
conditions of the Federal award indicate otherwise.

NOTE: THIS TABLE MUST BE READ ALONG WITH THE OTHER PROVISIONS OF THIS SECTION.
The following portions of this Part Are applicable to the following types of Are NOT applicable to the following
Federal Awards and Fixed-Price Contracts types of Federal Awards and Fixed-
and Subcontracts (except as noted in Price Contracts and Subcontracts:
paragraphs (d) and (e) below):
Subpart A - Acronyms and Definitions — All
Subpart B - General Provisions, except for — All

§§200.11 English Language, 200.112 Conflict of
Interest, 200.113 Mandatory Disclosures.
§§200.111 English Language, 200.112 Conflict —Grants agreements and cooperative agreements — Agreement for loans, loan guarantees,
of Interest, 200.113 Mandatory Disclosures interest subsidies, and insurance.
— Procurement contracts awarded by
Federal Agencies under the Federal
Acquisition Regulation and subcontracts
under those contracts.
Subparts C-D, except for §§200.202 —Grants agreements and cooperative agreements — Agreement for loans, loan guarantees,
Requirement to provide public notice of Federal interest subsidies, and insurance.
financial assistance programs, 200.303 Internal — Procurement contracts awarded by
controls, 200.330-332 Subrecipient Monitoring Federal Agencies under the Federal
and Management Acquisition Regulation and subcontracts
under those contracts.
§200.202 Requirement to provide public notice of — Grants agreements and cooperative — Procurement contracts awarded by
Federal financial assistance programs. agreements Federal Agencies under the Federal
— All procurement contracts under the Federal Acquisition Regulation and subcontracts
Acquisition Regulations except those that are under those contracts.
not negotiated
§§200.303 Internal controls, 200.330-332 — All

Subrecipient Monitoring and Management

The following portions of this Part Are applicable to the following types of Are NOT applicable to the following
Federal Awards and Fixed-Price Contracts types of Federal Awards and Fixed-
and Subcontracts (except as noted in Price Contracts and Subcontracts:
paragraphs (d) and (e) below):
Subpart E - Cost Principles — Grant Agreements and cooperative — Grant agreements and cooperative
agreements, except those providing food agreements providing food commodities.
commodities — Fixed amount awards.
— All procurement contracts under the Federal — Agreements for loans, loan guarantees,
Acquisition Regulation except those that are interest subsidies, and insurance.
not negotiated — Federal awards to hospitals (see
Appendix IX Hospital Cost Principles).
Subpart F - Audit Requirements — Grant Agreements and cooperative — Fixed-price contracts and subcontracts
agreements awarded under the Federal Acquisition
— Contracts and subcontracts, except for fixed Regulation.
price contracts and subcontracts, awarded
under the Federal Acquisition Regulation
— Agreements for loans, loan guarantees,
interest subsidies and insurance and other
forms of Federal Financial Assistance as
defined by the Single Audit Act Amendment of
1996

(2) Federal award of cost-reimbursement contract under the

FAR to a non-Federal entity. When a non-Federal entity is
awarded a cost-reimbursement contract, only Subpart D—Post
Federal Award Requirements of this part, §§200.330
Subrecipient and contractor determinations through 200.332
Fixed amount Subawards (in addition to any FAR related
requirements for subaward monitoring), Subpart E—Cost
Principles of this part and Subpart F—Audit Requirements of
this part are incorporated by reference into the contract.
However, when the Cost Accounting Standards (CAS) are
applicable to the contract, they take precedence over the
requirements of this part except for Subpart F—Audit
Requirements of this part when they are in conflict. In addition,
costs that are made unallowable under 10 U.S.C. 2324(e) and
41 U.S.C. 4304(a) as described in the FAR subpart 31.2 and
subpart 31.603 are always unallowable. For requirements other
than those covered in Subpart D—Post Federal Award
Requirements of this part, §§200.330 Subrecipient and
contractor determinations through 200.332 Fixed amount
Subawards, Subpart E—Cost Principles of this part and Subpart
F—Audit Requirements of this part, the terms of the contract
and the FAR apply.
(3) With the exception of Subpart F—Audit Requirements of this

part, which is required by the Single Audit Act, in any
circumstances where the provisions of Federal statutes or
regulations differ from the provisions of this part, the provision of
the Federal statutes or regulations govern. This includes, for
agreements with Indian tribes, the provisions of the Indian Self-
Determination and Education and Assistance Act (ISDEAA), as
amended, 25 U.S.C 450-458ddd-2.
(c) Federal awarding agencies may apply subparts A through E

of this part to for-profit entities, foreign public entities, or foreign
organizations, except where the Federal awarding agency
determines that the application of these subparts would be
inconsistent with the international obligations of the United
States or the statutes or regulations of a foreign government.
(d) Except for §200.202 Requirement to provide public notice of

Federal financial assistance programs and §§200.330
Subrecipient and contractor determinations through 200.332
Fixed amount Subawards of Subpart D—Post Federal Award
Requirements of this part, the requirements in Subpart C—Pre-
Federal Award Requirements and Contents of Federal Awards,
Subpart D—Post Federal Award Requirements of this part, and
Subpart E—Cost Principles of this part do not apply to the
following programs:
(1) The block grant awards authorized by the Omnibus Budget

Reconciliation Act of 1981 (including Community Services),
except to the extent that Subpart E—Cost Principles of this Part
apply to subrecipients of Community Services Block Grant funds

pursuant to 42 U.S.C. 9916(a)(1)(B);
(2) Federal awards to local education agencies under 20 U.S.C.

7702-7703b, (portions of the Impact Aid program);
(3) Payments under the Department of Veterans Affairs' State

Home Per Diem Program (38 U.S.C. 1741); and
(4) Federal awards authorized under the Child Care and

Development Block Grant Act of 1990, as amended:
(i) Child Care and Development Block Grant (42 U.S.C. 9858)
(ii) Child Care Mandatory and Matching Funds of the Child Care
and Development Fund (42 U.S.C. 9858)
(e) Except for §200.202 Requirement to provide public notice of

Federal financial assistance programs the guidance in Subpart
C—Pre-Federal Award Requirements and Contents of Federal
Awards of this part does not apply to the following programs:
(1) Entitlement Federal awards to carry out the following

programs of the Social Security Act:
(i) Temporary Assistance to Needy Families (title IV-A of the

Social Security Act, 42 U.S.C. 601-619);
(ii) Child Support Enforcement and Establishment of Paternity

(title IV-D of the Social Security Act, 42 U.S.C. 651-669b);
(iii) Foster Care and Adoption Assistance (title IV-E of the Act,
42 U.S.C. 670-679c);
(iv) Aid to the Aged, Blind, and Disabled (titles I, X, XIV, and
XVI-AABD of the Act, as amended);
(v) Medical Assistance (Medicaid) (title XIX of the Act, 42 U.S.C.

1396-1396w-5) not including the State Medicaid Fraud Control
program authorized by section 1903(a)(6)(B) of the Social
Security Act (42 U.S.C. 1396b(a)(6)(B)); and
(vi) Children's Health Insurance Program (title XXI of the Act, 42

U.S.C. 1397aa-1397mm).
(2) A Federal award for an experimental, pilot, or demonstration

project that is also supported by a Federal award listed in
paragraph (e)(1) of this section;
(3) Federal awards under subsection 412(e) of the Immigration

and Nationality Act and subsection 501(a) of the Refugee
Education Assistance Act of 1980 (Pub. L. 96-422, 94 Stat.
1809), for cash assistance, medical assistance, and
supplemental security income benefits to refugees and entrants

and the administrative costs of providing the assistance and

benefits (8 U.S.C. 1522(e));
(4) Entitlement awards under the following programs of The

National School Lunch Act:
(i) National School Lunch Program (section 4 of the Act, 42

U.S.C. 1753),
(ii) Commodity Assistance (section 6 of the Act, 42 U.S.C.

1755),
(iii) Special Meal Assistance (section 11 of the Act, 42 U.S.C.

1759a),
(iv) Summer Food Service Program for Children (section 13 of

the Act, 42 U.S.C. 1761), and
(v) Child and Adult Care Food Program (section 17 of the Act,
42 U.S.C. 1766).
(5) Entitlement awards under the following programs of The

Child Nutrition Act of 1966:
(i) Special Milk Program (section 3 of the Act, 42 U.S.C. 1772),
(ii) School Breakfast Program (section 4 of the Act, 42 U.S.C.

1773), and
(iii) State Administrative Expenses (section 7 of the Act, 42

U.S.C. section 1776).
(6) Entitlement awards for State Administrative Expenses under

The Food and Nutrition Act of 2008 (section 16 of the Act, 7
U.S.C. 2025).
(7) Non-discretionary Federal awards under the following non-

entitlement programs:
(i) Special Supplemental Nutrition Program for Women, Infants

and Children (section 17 of the Child Nutrition Act of 1966) 42
U.S.C. section 1786;
(ii) The Emergency Food Assistance Programs (Emergency

Food Assistance Act of 1983) 7 U.S.C. section 7501 note; and
(iii) Commodity Supplemental Food Program (section 5 of the

Agriculture and Consumer Protection Act of 1973) 7 U.S.C.
section 612c note.

The Uniform Guidance does not supersede program specific authorities or other statutes. When
there is a conflict between 2 CFR 200 and a statute, the statute’s provisions govern. 2 CFR
200.101(b)(3) identifies the Indian Self-Determination and Education and Assistance Act (ISDEAA)
a specific statute that would take precedence over 2 CFR 200.
Under 2 CFR 200.101(c), federal awarding agencies may apply the Uniform Guidance to for-profit
entities, foreign public entities, and foreign organizations. Federal awarding agencies can apply the
requirements through implementing regulations, program requirements, or through the award terms
and conditions.
2 CFR 200.101(d) and 2 CFR 200.101(e) identify select federal programs that are exempt from the
certain or all provisions of the Uniform Guidance. Programs identified include, but are not limited to,
certain entitlement and block grant programs.

2.1.3 §200.102 Exceptions

§200.102 Exceptions.
(a) With the exception of Subpart F—Audit Requirements of this

part, OMB may allow exceptions for classes of Federal awards
or non-Federal entities subject to the requirements of this part
when exceptions are not prohibited by statute. However, in the
interest of maximum uniformity, exceptions from the
requirements of this part will be permitted only in unusual
circumstances. Exceptions for classes of Federal awards or
non-Federal entities will be published on the OMB Web site at
www.whitehouse.gov/omb.
(b) Exceptions on a case-by-case basis for individual non-

Federal entities may be authorized by the Federal awarding
agency or cognizant agency for indirect costs, except where
otherwise required by law or where OMB or other approval is
expressly required by this part.
(c) The Federal awarding agency may apply more restrictive

requirements to a class of Federal awards or non-Federal
entities when approved by OMB, or when, required by Federal
statutes or regulations, except for the requirements in Subpart
F—Audit Requirements of this part. A Federal awarding agency
may apply less restrictive requirements when making fixed
amount awards as defined in Subpart A—Acronyms and
Definitions of this part, except for those requirements imposed
by statute or in Subpart F—Audit Requirements of this part.
(d) On a case-by-case basis, OMB will approve new strategies

for Federal awards when proposed by the Federal awarding
agency in accordance with OMB guidance (such as M-13-17) to
develop additional evidence relevant to addressing important
policy challenges or to promote cost-effectiveness in and across
Federal programs. Proposals may draw on the innovative
program designs discussed in M-13-17 to expand or improve
the use of effective practices in delivering Federal financial
assistance while also encouraging innovation in service
delivery. Proposals submitted to OMB in accordance with M-13-
17 may include requests to waive requirements other than those
in Subpart F—Audit Requirements of this part.
OMB can grant exceptions to classes of federal awards or to non-federal entities; however, 2 CFR
200.102 states that to ensure maximum uniformity, exceptions will only be permitted in “unusual
circumstances.” The Single Audit Act prohibits OMB from granting exceptions to any requirement
found in Subpart F – Audit Requirements. Federal agencies may, with OMB approval, apply more
restrictive requirements to a class of federal awards. Less restrictive requirements may only be
implemented to fixed amount awards. See Resource, Agency-Specific Exceptions, for a list of all
agency-specific exceptions to 2 CFR 200.

2 CFR 200.102 also enables OMB to provide exceptions to the Uniform Guidance for federal
awards on a case-by-case basis. Exceptions can be approved when federal agencies propose new
strategies that align with OMB Memorandum M-13-17, Next Steps in the Evidence and Innovation
Agenda. M-13-17 encourages federal agencies to expand upon, or improve the use of, effective
practices in delivering financial assistance. Examples may include the use of fixed amount awards,
tiered-evidence grants, pay for success initiatives, and the development of performance
partnerships. Successful implementation of these strategies should result in reduced burdens on
the non-federal entity and improved performance outcomes.
Refer to Website
M-13-17 can be found at:

https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/memoranda/20
13/m-13-17.pdf
OMB granted exceptions to the following agencies from certain requirements in the Uniform
Guidance:
 Agency for International Development
 Corporation for National and Community Service
 Department of Agriculture
 Department of Defense
 Department of Education
 Department of Energy
 Department of Health and Human Services
 Department of the Interior
 Department of Justice
 Department of Labor
 Department of State
 Department of Transportation
 Department of the Treasury
 Environmental Protection Agency
 National Aeronautics and Space Administration
 National Archives and Records Administration
 National Science Foundation
 Small Business Administration
2.1.4 §200.103 Authorities

This section identifies the statutes, executive orders, and other guidance under which the Uniform
Guidance was issued.

§200.103 Authorities.
This part is issued under the following authorities.
(a) Subpart B—General Provisions of this part through Subpart

D—Post Federal Award Requirements of this part are
authorized under 31 U.S.C. 503 (the Chief Financial Officers
Act, Functions of the Deputy Director for Management), 31
U.S.C. 1111 (Improving Economy and Efficiency of the United
States Government), 41 U.S.C. 1101-1131 (the Office of
Federal Procurement Policy Act), Reorganization Plan No. 2 of
1970, and Executive Order 11541 (“Prescribing the Duties of the
Office of Management and Budget and the Domestic Policy
Council in the Executive Office of the President”), the Single
Audit Act Amendments of 1996, (31 U.S.C. 7501-7507), as well
as The Federal Program Information Act (Public Law 95-220
and Public Law 98-169, as amended, codified at 31 U.S.C.
6101-6106).
(b) Subpart E—Cost Principles of this part is authorized under

the Budget and Accounting Act of 1921, as amended; the
Budget and Accounting Procedures Act of 1950, as amended
(31 U.S.C. 1101-1125); the Chief Financial Officers Act of 1990
(31 U.S.C. 503-504); Reorganization Plan No. 2 of 1970; and
Executive Order No. 11541, “Prescribing the Duties of the Office
of Management and Budget and the Domestic Policy Council in
the Executive Office of the President.”
(c) Subpart F—Audit Requirements of this part is authorized

under the Single Audit Act Amendments of 1996, (31 U.S.C.
7501-7507).
2.1.5 §200.104 Supersession

This section identifies the previous grants-related guidance that are superseded by 2 CFR 200.

§200.104 Supersession.
As described in §200.110 Effective/applicability date, this part

supersedes the following OMB guidance documents and
regulations under Title 2 of the Code of Federal Regulations:
(a) A-21, “Cost Principles for Educational Institutions” (2 CFR

part 220);
(b) A-87, “Cost Principles for State, Local and Indian Tribal
Governments” (2 CFR part 225) and also Federal Register
notice 51 FR 552 (January 6, 1986);
(c) A-89, “Federal Domestic Assistance Program Information”;
(d) A-102, “Grant Awards and Cooperative Agreements with

State and Local Governments”;
(e) A-110, “Uniform Administrative Requirements for Awards

and Other Agreements with Institutions of Higher Education,
Hospitals, and Other Nonprofit Organizations” (codified at 2
CFR 215);
(f) A-122, “Cost Principles for Non-Profit Organizations” (2 CFR

part 230);
(g) A-133, “Audits of States, Local Governments and Non-Profit

Organizations ”; and
(h) Those sections of A-50 related to audits performed under

Subpart F—Audit Requirements of this part.
Refer to Website
The Uniform Guidance can be can be obtained from the OMB

website at:
https://obamawhitehouse.archives.gov/omb/grants_docs.
2.1.6 §200.105 Effect on Other Issuances

This section explains that all previous administrative requirements, program manuals, handbooks,
and other non-regulatory materials that are inconsistent with the Uniform Guidance are superseded,
unless required by statute or received OMB approval.

§200.105 Effect on other issuances.
For Federal awards subject to this part, all administrative

requirements, program manuals, handbooks and other non-
regulatory materials that are inconsistent with the requirements
of this part must be superseded upon implementation of this
part by the Federal agency, except to the extent they are
required by statute or authorized in accordance with the
provisions in §200.102 Exceptions.
2.1.7 §200.106 Agency Implementation

2 CFR 200.106 instructs federal awarding agencies to issue regulations implementing the Uniform
Guidance.
§200.106 Agency implementation.
The specific requirements and responsibilities of Federal

agencies and non-Federal entities are set forth in this part.
Federal agencies making Federal awards to non-Federal
entities must implement the language in the Subpart C—Pre-
Federal Award Requirements and Contents of Federal Awards
of this part through Subpart F—Audit Requirements of this part
in codified regulations unless different provisions are required
by Federal statute or are approved by OMB.
2.1.8 §200.107 OMB Responsibilities

Under the Uniform Guidance, OMB must review agency implementation regulations and issue
agency-specific exceptions where “adequate justification is presented.”
§200.107 OMB responsibilities.
OMB will review Federal agency regulations and implementation

of this part, and will provide interpretations of policy
requirements and assistance to ensure effective and efficient
implementation. Any exceptions will be subject to approval by
OMB. Exceptions will only be made in particular cases where
adequate justification is presented.
2.1.9 §200.108 Inquiries

This section indicates the appropriate contact for questions relating to the Uniform Guidance.

§200.108 Inquiries.
Inquiries concerning this part may be directed to the Office of

Federal Financial Management Office of Management and
Budget, in Washington, DC. Non-Federal entities' inquiries
should be addressed to the Federal awarding agency, cognizant
agency for indirect costs, cognizant or oversight agency for
audit, or pass-through entity as appropriate.
2.1.10 §200.109 Review Date

OMB is required to review 2 CFR 200 at least every five years.
§200.109 Review date.
OMB will review this part at least every five years after
December 26, 2013.
2.1.11 §200.110 Effective/Applicability Date

Except for the audit requirements found in Subpart F, the Uniform Guidance is applicable for all
federal awards issued on or after December 26, 2014. Federal awarding agencies may apply the
requirement under 2 CFR 200 to older awards if they receive additional funding (funding
increments) and the federal awarding agency issues new award terms and conditions. For all other
awards issued before December 26, 2014, the previous guidance identified in the award terms and
conditions will continue to govern until the end date of the award. Non-federal entities may apply
entity-wide system changes to comply with the Uniform Guidance to existing awards.
The audit requirements are applicable to a non-federal entity for the first full fiscal year on the non-
federal entity beginning on or after December 26, 2014. For prior fiscal years, OMB Circular A-133
must be used for audit requirements.
Indirect cost rates for non-federal entities will remain in effect until they are renegotiated. Federal
awarding agencies will use the Uniform Guidance to renegotiate an indirect cost rate for a non-
federal entity for the fiscal year beginning on or after December 26, 2014.
The Uniform Guidance provides non-federal entities with a grace period to implement the
procurement standards found in 2 CFR 200.317 through 2 CFR 200.326. Under 2 CFR 200.110(a),
non-federal entities are authorized to use procurement standards found in previous grants guidance
for up to three full fiscal years after December 26, 2014. Non-federal entities that opt for the grace
period must document this decision in their internal procurement policies.

§200.110 Effective/applicability date.
(a) The standards set forth in this part which affect

administration of Federal awards issued by Federal awarding
agencies become effective once implemented by Federal
awarding agencies or when any future amendment to this part
becomes final. Federal awarding agencies must implement the
policies and procedures applicable to Federal awards by
promulgating a regulation to be effective by December 26, 2014
unless different provisions are required by statute or approved
by OMB. For the procurement standards in §§200.317-200.326,
non-Federal entities may continue to comply with the
procurement standards in previous OMB guidance (superseded
by this part as described in §200.104) for two additional fiscal
years after this part goes into effect. If a non-Federal entity
chooses to use the previous procurement standards for an
additional two fiscal years before adopting the procurement
standards in this part, the non-Federal entity must document
this decision in their internal procurement policies.
(b) The standards set forth in Subpart F—Audit Requirements of

this part and any other standards which apply directly to Federal
agencies will be effective December 26, 2013 and will apply to
audits of fiscal years beginning on or after December 26, 2014.
2.1.12 §200.111 English Language

The Uniform Guidance requires all federal financial assistance announcements and award
information be published in the English language. Applicants, including foreign non-federal entities,
are required to submit applications that are written in the English language and use the U.S. dollar.
Non-federal entities with a "significant portion" of non-English speaking employees must submit an
application in both English and the predominant language of the nonfederal entity's employees.
When inconsistencies exist between the English application and the native language application,
the English language application will serve as the guiding document.

§200.111 English language.
(a) All Federal financial assistance announcements and Federal

award information must be in the English language. Applications
must be submitted in the English language and must be in the
terms of U.S. dollars. If the Federal awarding agency receives
applications in another currency, the Federal awarding agency
will evaluate the application by converting the foreign currency
to United States currency using the date specified for receipt of
the application.
(b) Non-Federal entities may translate the Federal award and

other documents into another language. In the event of
inconsistency between any terms and conditions of the Federal
award and any translation into another language, the English
language meaning will control. Where a significant portion of the
non-Federal entity's employees who are working on the Federal
award are not fluent in English, the non-Federal entity must
provide the Federal award in English and the language(s) with
which employees are more familiar.
2.1.13 §200.112 Conflict of Interest

2 CFR 200.112 requires federal awarding agencies to establish conflict of interest policies for
federal awards. In turn, non-federal entities must adopt internal conflict of interest policies that align
with the policy of their funding agencies. The Uniform Guidance requires non-federal entities to
disclose, in writing, any potential conflict of interest to the applicable federal awarding agency or
pass-through entity. The Uniform Guidance provides flexibility to federal awarding agencies in
developing specific policy requirements.
§200.112 Conflict of interest.
The Federal awarding agency must establish conflict of interest

policies for Federal awards. The non-Federal entity must
disclose in writing any potential conflict of interest to the Federal
awarding agency or pass-through entity in accordance with
applicable Federal awarding agency policy.

Requirements Concerning Conflict of Interest

Example: National Institutes of Health – Conflict of Interest

Definitions 1
A "Conflict of Interest" arises when an employee is involved in a

particular matter as part of his/her official duties with an outside
organization with which he/she also has a financial interest, or
one which is imputed to him/her, i.e., the employee's 1) spouse,
2) minor children, 3) general partner, 4) an organization in which
the employee serves as officer, director, trustee, partner, or
employee, or 5) a person or organization with which the
employee is negotiating for prospective or has an arrangement
for prospective employment. Conflicts can be real or apparent.
A real conflict exists when an employee participates personally
and substantially in particular matters that have a direct and
predictable effect on a financial interest of the employee, or one
of the five 'others' listed above. In this case, participation in the
official matter is in violation of statute 18 U.S.C. 208. If the
Deputy Ethics Counselor determines that the financial interest is
not "so substantial as to be deemed likely to affect the integrity
of the services with the Government may expect" from the
employee, a waiver granting permission to participate in the
official matter may be given.
An appearance of a conflict exists when an employee is

involved in a particular matter involving specific outside parties
(including individual, corporate entities, etc) and the
circumstances are such that a reasonable person with
knowledge of the relevant facts would question the employee's
impartiality in the matter. Such circumstances include the
involvement of a relative, spousal employer, or former employer
in the matter. In this case, the Deputy Ethics Counselor could
determine that it is in the best interests of the Government for
that employee to be involved in that particular matter, despite
the appearance of a conflict, and authorize the employee to
participate.
Employees who have financial interests (outside employment,

stocks and other financial holdings) of their own, or financial
interests of anyone listed in the first paragraph above which are
imputed to them, must disclose any conflict and work with the
Deputy Ethics Counselor or Ethics Coordinator to obtain a
waiver or authorization, or be disqualified from participating in
particular matters concerning the outside entity.
1
NIH Ethics Program, National Institutes of Health. “Conflicts of Interest.” Feb 19, 2013. Web. March 14, 2016.

Example: Office of Justice Programs – Conflicts of Interest

2
Personnel and other officials connected with agency-funded

programs shall adhere to the following requirements:
ADVICE
No official or employee of a State or unit of local government or

a nongovernmental recipient/subrecipient shall participate
personally through decisions, approval, disapproval,
recommendation, the rendering of advice, investigation, or
otherwise in any proceeding, application, request for a ruling or
other determination, contract, award, cooperative agreement,
claim, controversy, or other particular matter in which award
funds (including program income or other funds generated by
federally funded activities) are used, where to his/her
knowledge, he/she or his/her immediate family, partners,
organization other than a public agency in which he/she is
serving as an officer, director, trustee, partner, or employee, or
any person or organization with whom he/she is negotiating or
has any arrangement concerning prospective employment, has
a financial interest, or has less than an arms-length transaction.
APPEARANCE
In the use of agency project funds, officials or employees of

State or local units of government and nongovernmental
recipient/subrecipient shall avoid any action, which might result
in, or create the appearance of:
Using his or her official position for private gain;

Giving preferential treatment to any person;
Losing complete independence or impartiality;
Making an official decision outside official channels; or
Affecting adversely the confidence of the public in the
integrity of the Government or the program.
For example, where a recipient of Federal funds makes

subawards under any competitive process and an actual conflict
or an appearance of a conflict of interest exists, the person for
whom the actual or apparent conflict of interest exists should
recuse himself or herself not only from reviewing the application
for which the conflict exists, but also from the evaluation of all
competing applications.
Also, it is a conflict of interest for a board member of a nonprofit

organization to receive consulting fees or contracts from Federal
grants to organizations that he/she oversees as a member of
2
Office of Justice Programs, U.S. Department of Justice. “Conflicts of Interest.” Web. March 14, 2016.

the board, unless approved in advance by the awarding agency.
Discussion
What is your entity's conflict of interest policy?

2.1.13.1 Exercise: Reviewing a Conflict of Interest Policy

Directions
Read the Conflict of Interest Policy resource. It is also located at

https://www.epa.gov/grants/epas-financial-assistance-conflict-interest-policy
Answer the questions provided.
1. Which entities must adhere to the EPA’s conflict of interest policy?
2. What are the responsibilities of non-federal entities regarding the COI Point of Contact?
3. What are the situations that require a non-federal entity to disclose a conflict of interest policy?
4. How does this policy affect pass-through entities?
5. The policy requires non-federal entities to “have systems in place to address, resolve, and
disclose” conflict of interest situations. What processes might a non-federal entity have to meet
this requirement?

6. When must the non-federal entity disclose conflict of interest situations?
7. What information must be in the conflict of interest disclosure?

2.1.14 §200.113 Mandatory Disclosures

§200.113 Mandatory disclosures. 3
The non-Federal entity or applicant for a Federal award must

disclose, in a timely manner, in writing to the Federal awarding
agency or pass-through entity all violations of Federal criminal
law involving fraud, bribery, or gratuity violations potentially
affecting the Federal award. Non-Federal entities that have
received a Federal award including the term and condition
outlined in Appendix XII—Award Term and Condition for
Recipient Integrity and Performance Matters are required to
report certain civil, criminal, or administrative proceedings to
SAM. Failure to make required disclosures can result in any of
the remedies described in §200.338 Remedies for
noncompliance, including suspension or debarment. (See also 2
CFR part 180, 31 U.S.C. 3321, and 41 U.S.C. 2313.)
2 CFR 200.113 requires non-federal entities to establish and implement internal policies to disclose
all violations of federal criminal law involving fraud, bribery, or gratuity violations that may potentially
affect a federal award.
An adequate policy should indicate:
 The employee(s) responsible for identifying violations that may potentially affect a federal award
 The employee(s) responsible for notifying the federal awarding agency or pass-through entity of
violations
 The method in which the organization will provide written notification to the federal awarding
agency or pass-through entity
 A definition of “timely manner” in which the non-federal entity will notify the federal awarding
agency or pass-through entity
 A list of applicable federal laws involving fraud and bribery
 A definition of “gratuity violations.”
When drafting this policy, a non-federal entity should work closely with their legal counsel. Under 2
CFR 200.113, a non-federal entity must notify a federal awarding agency or pass-through entity of a
violation of federal criminal law, and not just when an arrest, indictment, or conviction has occurred.
This requirement could potentially present legal consequences for a non-federal entity, therefore it
is critical that legal counsel be involved.
The policy should also provide an adequate definition of a “gratuity violation.” 2 CFR 200.318(c)(1)
reads, in part:
The officers, employees, and agents of the non-Federal entity may neither solicit nor
accept gratuities, favors, or anything of monetary value from contractors or parties to
subcontracts. However, non-Federal entities may set standards for situations in
which the financial interest is not substantial or the gift is an unsolicited item of
3
United States Agency of International Development,Standard Provisions forU.S. Nongovernmental Organizations

nominal value. The standards of conduct must provide for disciplinary actions to be
applied for violations of such standards by officers, employees, or agents of the non-
Federal entity.
Therefore, an adequate internal policy must:

 Explicitly prohibit employees from soliciting or accepting “gratuities, favors, or anything of
monetary value from contractors or parties to subcontracts”
 Explain when an “unsolicited item of nominal value” may be accepted
 Detail the consequences for employees that violate this policy
It is important that the policy clearly defines “nominal value.” Non-federal entities have the discretion
to set the nominal value that best meets their entity’s needs; however, caution should be applied if
the threshold is set a value that may influence an employee’s actions. An adequate policy will detail
how an employee reports items of nominal value, how the item is appraised, and the types of items
that may be accepted.
Non-federal entities should be aware that failure to adopt and implement an adequate policy may
result in the Federal awarding agency or pass-through entity in applying sanctions for non-
compliance. 2 CFR 200.338 identifies possible sanctions that may include temporarily withholding
payments, disallowing costs, initiating suspension and debarment procedures, and terminating an
award. A non-federal entity could also face additional civil and criminal penalties for violations.
2 CFR 200.113 also requires all non-federal entities subject to Appendix XII of 2 CFR 200 to report
certain civil, criminal, or administrative proceedings to SAM.gov. Appendix XII of 2 CFR 200 applies
to any non-federal entity that has active grants, cooperative agreements, and procurement
contracts in excess of $10,000,000 for any period of time. Non-federal entities subject to Appendix
XII of 2 CFR 200 must report either new information or affirm that there is no new information to
report on a semiannual basis.

Example: USAID Mandatory Disclosures Requirement

Policy
Consistent with 2 CFR §200.113, applicants and recipients must

disclose, in a timely manner, in writing to the USAID Office of
the Inspector General, with a copy to the cognizant Agreement
Officer, all violations of Federal criminal law involving fraud,
bribery, or gratuity violations potentially affecting the Federal
award. Subrecipients must disclose, in a timely manner, in
writing to the USAID Office of the Inspector General and to the
prime recipient (pass through entity) all violations of Federal
criminal law involving fraud, bribery, or gratuity violations
potentially affecting the Federal award.
Disclosures must be sent to:

U.S. Agency for International Development
Office of the Inspector General
P.O. Box 657
Washington, DC 20044-0657
Phone: 1-800-230-6539 or 202-712-1023
Failure to make required disclosures can result in any of the

remedies described in 2 CFR §200.338 Remedies for
noncompliance, including suspension or debarment (See 2 CFR
180, 2 CFR 780 and 31 U.S.C. 3321).
The recipient must include this mandatory disclosure

requirement in all subawards and contracts under this award.
Discussion
What steps has your entity taken to address the requirements

under 2 CFR 200.113?
Action Planning
module.

Pre-Federal Award
Requirements and
Contents of Federal
Awards (2 CFR 200 Subpart
C)
MODULE 3 | PRE-FEDERAL AWARD REQUIREMENTS AND CONTENTS OF FEDERAL AWARDS (2 CFR
200 SUBPART C)
PRE-FEDERAL AWARD
REQUIREMENTS AND CONTENTS OF
FEDERAL AWARDS (2 CFR 200
SUBPART C)
Module Objective
 Identify the pre-award requirements for federal awarding agencies and describe how they

200 SUBPART C)
Federal Grant Award Process
Lessons
1. Federal Award Instruments
2. Notices of Federal Financial Assistance
3. Merit Review Process
4. Pre-award Risk Assessment
5. Application Forms
6. Specific Conditions
7. Certifications and Representations

200 SUBPART C)
8. Federal Award Document
9. Information that Becomes Public
10. Remedies for Noncompliance

200 SUBPART C)

200 SUBPART C)
LESSON 1
FEDERAL AWARD INSTRUMENTS
Lesson Objective
3.1.1 Select the appropriate federal award instrument
1.1 §200.200 PURPOSE OF SUBPART C

§200.200 Purpose.
(a) Sections 200.201 Use of grant agreements (including fixed

amount awards), cooperative agreements, and contracts
through 200.208 Certifications and representations prescribe
instructions and other pre-award matters to be used in the
announcement and application process.
(b) Use of §§200.203 Notices of funding opportunities, 200.204

Federal awarding agency review of merit of proposals, 200.205
Federal awarding agency review of risk posed by applicants,
and 200.207 Specific conditions, is required only for competitive
Federal awards, but may also be used by the Federal awarding
agency for non-competitive awards where appropriate or where
required by Federal statute.

LESSON 1 | FEDERAL AWARD INSTRUMENTS
1.2 §200.201 USE OF GRANT AGREEMENTS (INCLUDING FIXED

AMOUNT AWARDS), COOPERATIVE AGREEMENTS, AND
CONTRACTS
§200.201 Use of grant agreements (including fixed amount
awards), cooperative agreements, and contracts.
(a) The Federal awarding agency or pass-through entity must

decide on the appropriate instrument for the Federal award (i.e.,
grant agreement, cooperative agreement, or contract) in
accordance with the Federal Grant and Cooperative Agreement
Act (31 U.S.C. 6301-08).
(b) Fixed Amount Awards. In addition to the options described in

paragraph (a) of this section, Federal awarding agencies, or
pass-through entities as permitted in §200.332 Fixed amount
subawards, may use fixed amount awards (see §200.45 Fixed
amount awards) to which the following conditions apply:
(1) The Federal award amount is negotiated using the cost

principles (or other pricing information) as a guide. The Federal
awarding agency or pass-through entity may use fixed amount
awards if the project scope is specific and if adequate cost,
historical, or unit pricing data is available to establish a fixed
amount award based on a reasonable estimate of actual cost.
Payments are based on meeting specific requirements of the
Federal award. Accountability is based on performance and
results. Except in the case of termination before completion of
the Federal award, there is no governmental review of the
actual costs incurred by the non-Federal entity in performance
of the award. Some of the ways in which the Federal award may
be paid include, but are not limited to:
(i) In several partial payments, the amount of each agreed upon

in advance, and the “milestone” or event triggering the payment
also agreed upon in advance, and set forth in the Federal
award;
(ii) On a unit price basis, for a defined unit or units, at a defined

price or prices, agreed to in advance of performance of the
Federal award and set forth in the Federal award; or,
(iii) In one payment at Federal award completion.
(2) A fixed amount award cannot be used in programs which

require mandatory cost sharing or match.
(3) The non-Federal entity must certify in writing to the Federal

awarding agency or pass-through entity at the end of the
Federal award that the project or activity was completed or the
level of effort was expended. If the required level of activity or
effort was not carried out, the amount of the Federal award must
be adjusted.

200 SUBPART C)
(4) Periodic reports may be established for each Federal award.
(5) Changes in principal investigator, project leader, project

partner, or scope of effort must receive the prior written approval
of the Federal awarding agency or pass-through entity.
Federal awarding agencies and pass-through entities must decide on the appropriate instrument for
making a federal award. The instrument used must be in accordance with the Federal Grant and
Cooperative Agreement Act (31 U.S.C. 6301-08). Section 200.201(a) identifies the following
available instruments:
 Grant agreement (§200.51)
 Contract (§200.22)
 Fixed amount award (§200.45)
A fixed amount award is a new funding instrument available to awarding agencies under the
Uniform Guidance. The concept of fixed amount awards extends from OMB Memorandum M-13-17,
Next Steps in the Evidence and Innovation Agenda. Fixed amount awards are designed to focus
more on the non-federal entity's project performance rather than on its compliance with
administrative requirements. The non-federal entity must meet specific performance requirements,
as identified in the award, to receive payment.
Refer to Website

https://obamawhitehouse.archives.gov/sites/default/files/omb/memoranda/2
013/m-13-17.pdf
To reduce the administrative burden on non-federal entities, the cost principles are used only as a
guide during award negotiations for fixed amount awards. After the award, there is no review of
actual costs incurred to the award. The awarding agency, however, may require periodic financial
and progress reports from the non-federal entity.
Pass-through entities may also award fixed amount subawards (2 CFR 200.332). The federal
agency must provide prior approval before a fixed amount subaward is made. A fixed amount
subaward cannot be in excess of the Simplified Acquisition Threshold. All fixed amount subawards
must adhere to the requirements and provisions for fixed amount awards.

LESSON 1 | FEDERAL AWARD INSTRUMENTS
Cost Reimbursement Grants Versus Fixed Amount Awards
Discussion
Have you ever used or considered using a fixed amount award?

200 SUBPART C)
LESSON 2
NOTICES OF FEDERAL FINANCIAL
ASSISTANCE
Lesson Objective
3.2.1 Describe the requirements for a Notice of Federal Financial Assistance.

LESSON 2 | NOTICES OF FEDERAL FINANCIAL ASSISTANCE
2.1 §200.202 REQUIREMENTS TO PROVIDE PUBLIC NOTICE OF

FEDERAL FINANCIAL ASSISTANCE PROGRAMS
Federal Grant Award Process, Step One: Publish CFDA Notice
Federal awarding agencies are required to develop a public notice of federal financial assistance
program for each program for an Assistance Listings Notice (Formerly known as the Catalog of
Federal Domestic Assistance [CFDA]). The CFDA is the government-wide resource identifying
federal programs, projects, services, and activities that provide assistance or benefits to the
American public. It contains financial and nonfinancial assistance programs administered by
departments and establishments of the Federal government.
The purpose of Assistance Listings is to provide general information about each federal financial
assistance program. The Assistance Listings are designed to assist non-federal entities in
identifying potential funding sources. Federal awarding agencies must develop an Assistance
Listings notice before making an award, unless exigent circumstances exist.

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2 CFR 200.202 requires each Assistance Listings Notice to contain the following information:
 Program description, purpose, goals, and measurement
 Identification of whether the program makes discretionary or mandatory grants
 Projected total amount of funds available for the program
 Anticipated source of available funds
 General eligibility requirements
 Applicability of Single Audit Requirements under 2 CFR 200 Subpart F
Refer to Website
Assistance Listings (formerly known as the CFDA) can be

located at: https://beta.sam.gov/
Tip
Attention: In May 2018, the CFDA was moved to be part of the

SAM.gov system.
§200.202 Requirement to provide public notice of Federal

financial assistance programs.
(a) The Federal awarding agency must notify the public of

Federal programs in the Catalog of Federal Domestic
Assistance (CFDA), maintained by the General Services
Administration (GSA).
(1) The CFDA, or any OMB-designated replacement, is the

single, authoritative, governmentwide comprehensive source of
Federal financial assistance program information produced by
the executive branch of the Federal government.
(2) The information that the Federal awarding agency must

submit to GSA for approval by OMB is listed in paragraph (b) of
this section. GSA must prescribe the format for the submission.
(3) The Federal awarding agency may not award Federal

financial assistance without assigning it to a program that has
been included in the CFDA as required in this section unless
there are exigent circumstances requiring otherwise, such as
timing requirements imposed by statute.
(b) For each program that awards discretionary Federal awards,

non-discretionary Federal awards, loans, insurance, or any
other type of Federal financial assistance, the Federal awarding
agency must submit the following information to GSA:

(1) Program Description, Purpose, Goals and Measurement. A

brief summary of the statutory or regulatory requirements of the
program and its intended outcome. Where appropriate, the
Program Description, Purpose, Goals, and Measurement should
align with the strategic goals and objectives within the Federal
awarding agency's performance plan and should support the
Federal awarding agency's performance measurement,
management, and reporting as required by Part 6 of OMB
Circular A-11;
(2) Identification of whether the program makes Federal awards

on a discretionary basis or the Federal awards are prescribed
by Federal statute, such as in the case of formula grants.
(3) Projected total amount of funds available for the program.

Estimates based on previous year funding are acceptable if
current appropriations are not available at the time of the
submission;
(4) Anticipated Source of Available Funds: The statutory

authority for funding the program and, to the extent possible,
agency, sub-agency, or, if known, the specific program unit that
will issue the Federal awards, and associated funding identifier
(e.g., Treasury Account Symbol(s));
(5) General Eligibility Requirements: The statutory, regulatory or

other eligibility factors or considerations that determine the
applicant's qualification for Federal awards under the program
(e.g., type of non-Federal entity); and
(6) Applicability of Single Audit Requirements as required by

Subpart F—Audit Requirements of this part.
Activity: Review the CFDA (Assistance Listings) Notice
Review the CFDA (Assistance Listings) Notice for the Urban

Indian Health Services in Resource: CFDA (Assistance Listings)
Notice and NOFO for Urban Indian Health Services to determine
if each required element is presented.
 Program description, purpose, goals, and measurement
 Identification of whether the program makes discretionary or
mandatory grants
 Projected total amount of funds available for the program
 Anticipated source of available funds
 General eligibility requirements
 Applicability of Single Audit Requirements under 2 CFR 200
Subpart F

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2.2 §200.203 NOTICES OF FUNDING OPPORTUNITIES AND

APPENDIX I TO 2 CFR 200
Federal Grant Award Process, Step Two: Publish NOFO
2 CFR 200.203 establishes the procedures for federal awarding agencies to notify the public of
available grant opportunities. Federal agencies should publish a Notice of Funding Opportunity
(NOFO) generally 60 calendar days before the application deadline. The 60 calendar day time
frame is an expectation and not a requirement. 2 CFR 200.203(b) requires agencies, however, to
publish the notice at least 30 calendar days before the application deadline unless an "exigent
circumstance" occurs.
Under the Uniform Guidance, federal awarding agencies are required to publish the NOFO on the
OMB-designated government-wide website, currently Grants.gov. Federal awarding agencies are
not required to publish a NOFO in the Federal Register; however, some agencies, such as the
Department of Education, publish competition announcements concurrently on Grants.gov and in
the Federal Register.

Agencies are required to provide a synopsis of the funding opportunity. The required elements for
the summary are:
 Federal awarding agency name
 Funding opportunity title
 Indication if the notice is the initial announcement or a modification of a previously announced
opportunity
 Funding opportunity number
 CFDA number
 Key dates such as application deadlines and, if applicable, due dates for a pre-application or
letter of intent
The full text of the funding opportunity must include:
 A program description
 Federal award information
 Eligibility information
 Application and submission requirements
 Application review process
 Federal award administration information
 Federal awarding agency contact(s)
 Any other relevant information, as applicable

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§200.203 Notices of funding opportunities.
For competitive grants and cooperative agreements, the Federal

awarding agency must announce specific funding opportunities
by providing the following information in a public notice:
(a) Summary Information in Notices of Funding Opportunities.

The Federal awarding agency must display the following
information posted on the OMB-designated governmentwide
Web site for finding and applying for Federal financial
assistance, in a location preceding the full text of the
announcement:
(1) Federal Awarding Agency Name;
(2) Funding Opportunity Title;
(3) Announcement Type (whether the funding opportunity is the

initial announcement of this funding opportunity or a
modification of a previously announced opportunity);
(4) Funding Opportunity Number (required, if applicable). If the

Federal awarding agency has assigned or will assign a number
to the funding opportunity announcement, this number must be
provided;
(5) Catalog of Federal Domestic Assistance (CFDA) Number(s);
(6) Key Dates. Key dates include due dates for applications or
Executive Order 12372 submissions, as well as for any letters of
intent or pre-applications. For any announcement issued before
a program's application materials are available, key dates also
include the date on which those materials will be released; and
any other additional information, as deemed applicable by the
relevant Federal awarding agency.
(b) The Federal awarding agency must generally make all

funding opportunities available for application for at least 60
calendar days. The Federal awarding agency may make a
determination to have a less than 60 calendar day availability
period but no funding opportunity should be available for less
than 30 calendar days unless exigent circumstances require as
determined by the Federal awarding agency head or delegate.
(c) Full Text of Funding Opportunities. The Federal awarding

agency must include the following information in the full text of
each funding opportunity. For specific instructions on the
content required in this section, refer to Appendix I to Part 200—
Full Text of Notice of Funding Opportunity to this part.
(1) Full programmatic description of the funding opportunity.

(2) Federal award information, including sufficient information to

help an applicant make an informed decision about whether to
submit an application. (See also §200.414 Indirect (F&A) costs,
paragraph (c)(4)).
(3) Specific eligibility information, including any factors or

priorities that affect an applicant's or its application's eligibility
for selection.
(4) Application Preparation and Submission Information,

including the applicable submission dates and time.
(5) Application Review Information including the criteria and

process to be used to evaluate applications. See also
§§200.204 Federal awarding agency review of merit proposals
and 200.205 Federal awarding agency review of risk posed by
applicants.
(6) Federal Award Administration Information. See also

§200.210 Information contained in a Federal award.
Appendix I of the Uniform Guidance provides a template for the notice of funding opportunity and a
detailed explanation for each of the required elements.

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Appendix I to 2 CFR 200—Full Text of Notice of Funding

Opportunity
The full text of the notice of funding opportunity is organized in

sections. The required format outlined in this appendix indicates
immediately following the title of each section whether that
section is required in every announcement or is a Federal
awarding agency option. The format is designed so that similar
types of information will appear in the same sections in
announcements of different Federal funding opportunities.
Toward that end, there is text in each of the following sections to
describe the types of information that a Federal awarding
agency would include in that section of an actual
announcement.
A Federal awarding agency that wishes to include information

that the format does not specifically discuss may address that
subject in whatever section(s) is most appropriate. For example,
if a Federal awarding agency chooses to address performance
goals in the announcement, it might do so in the funding
opportunity description, the application content, or the reporting
requirements.
Similarly, when this format calls for a type of information to be in

a particular section, a Federal awarding agency wishing to
address that subject in other sections may elect to repeat the
information in those sections or use cross references between
the sections (there should be hyperlinks for cross-references in
any electronic versions of the announcement). For example, a
Federal awarding agency may want to include Section A
information about the types of non-Federal entities who are
eligible to apply. The format specifies a standard location for
that information in Section C.1 but does not preclude repeating
the information in Section A or creating a cross reference
between Section A and C.1, as long as a potential applicant can
find the information quickly and easily from the standard
location.
The sections of the full text of the announcement are described

in the following paragraphs.
A. Program Description—Required
This section contains the full program description of the funding

opportunity. It may be as long as needed to adequately
communicate to potential applicants the areas in which funding
may be provided. It describes the Federal awarding agency's
funding priorities or the technical or focus areas in which the
Federal awarding agency intends to provide assistance. As
appropriate, it may include any program history (e.g., whether
this is a new program or a new or changed area of program
emphasis). This section may communicate indicators of

successful projects (e.g., if the program encourages

collaborative efforts) and may include examples of projects that
have been funded previously. This section also may include
other information the Federal awarding agency deems
necessary, and must at a minimum include citations for
authorizing statutes and regulations for the funding opportunity.
B. Federal Award Information—Required
This section provides sufficient information to help an applicant

make an informed decision about whether to submit a proposal.
Relevant information could include the total amount of funding
that the Federal awarding agency expects to award through the
announcement; the anticipated number of Federal awards; the
expected amounts of individual Federal awards (which may be a
range); the amount of funding per Federal award, on average,
experienced in previous years; and the anticipated start dates
and periods of performance for new Federal awards. This
section also should address whether applications for renewal or
supplementation of existing projects are eligible to compete with
applications for new Federal awards.
This section also must indicate the type(s) of assistance

instrument (e.g., grant, cooperative agreement) that may be
awarded if applications are successful. If cooperative
agreements may be awarded, this section either should
describe the “substantial involvement” that the Federal awarding
agency expects to have or should reference where the potential
applicant can find that information (e.g., in the funding
opportunity description in A. Program Description—Required or
Federal award administration information in Section D.
Application and Submission Information). If procurement
contracts also may be awarded, this must be stated.
C. Eligibility Information
This section addresses the considerations or factors that

determine applicant or application eligibility. This includes the
eligibility of particular types of applicant organizations, any
factors affecting the eligibility of the principal investigator or
project director, and any criteria that make particular projects
ineligible. Federal agencies should make clear whether an
applicant's failure to meet an eligibility criterion by the time of an
application deadline will result in the Federal awarding agency
returning the application without review or, even though an
application may be reviewed, will preclude the Federal awarding
agency from making a Federal award. Key elements to be
addressed are:
1. Eligible Applicants—Required. Announcements must clearly

identify the types of entities that are eligible to apply. If there are
no restrictions on eligibility, this section may simply indicate that
all potential applicants are eligible. If there are restrictions on

200 SUBPART C)
eligibility, it is important to be clear about the specific types of

entities that are eligible, not just the types that are ineligible. For
example, if the program is limited to nonprofit organizations
subject to 26 U.S.C. 501(c)(3) of the tax code (26 U.S.C.
501(c)(3)), the announcement should say so. Similarly, it is
better to state explicitly that Native American tribal organizations
are eligible than to assume that they can unambiguously infer
that from a statement that nonprofit organizations may apply.
Eligibility also can be expressed by exception, (e.g., open to all
types of domestic applicants other than individuals). This
section should refer to any portion of Section D specifying
documentation that must be submitted to support an eligibility
determination (e.g., proof of 501(c)(3) status as determined by
the Internal Revenue Service or an authorizing tribal resolution).
To the extent that any funding restriction in Section D.6 could
affect the eligibility of an applicant or project, the announcement
must either restate that restriction in this section or provide a
cross-reference to its description in Section D.6.
2. Cost Sharing or Matching—Required. Announcements must

state whether there is required cost sharing, matching, or cost
participation without which an application would be ineligible (if
cost sharing is not required, the announcement must explicitly
say so). Required cost sharing may be a certain percentage or
amount, or may be in the form of contributions of specified items
or activities (e.g., provision of equipment). It is important that the
announcement be clear about any restrictions on the types of
cost (e.g., in-kind contributions) that are acceptable as cost
sharing. Cost sharing as an eligibility criterion includes
requirements based in statute or regulation, as described in
§200.306 Cost sharing or matching of this Part. This section
should refer to the appropriate portion(s) of section D.
Application and Submission Information stating any pre-award
requirements for submission of letters or other documentation to
verify commitments to meet cost-sharing requirements if a
Federal award is made.
3. Other—Required, if applicable. If there are other eligibility

criteria (i.e., criteria that have the effect of making an application
or project ineligible for Federal awards, whether referred to as
“responsiveness” criteria, “go-no go” criteria, “threshold” criteria,
or in other ways), must be clearly stated and must include a
reference to the regulation of requirement that describes the
restriction, as applicable. For example, if entities that have been
found to be in violation of a particular Federal statute are
ineligible, it is important to say so. This section must also state
any limit on the number of applications an applicant may submit
under the announcement and make clear whether the limitation
is on the submitting organization, individual investigator/program
director, or both. This section should also address any eligibility
criteria for beneficiaries or for program participants other than
Federal award recipients.

D. Application and Submission Information
1. Address to Request Application Package—Required.

Potential applicants must be told how to get application forms,
kits, or other materials needed to apply (if this announcement
contains everything needed, this section need only say so). An
Internet address where the materials can be accessed is
acceptable. However, since high-speed Internet access is not
yet universally available for downloading documents, and
applicants may have additional accessibility requirements, there
also should be a way for potential applicants to request paper
copies of materials, such as a U.S. Postal Service mailing
address, telephone or FAX number, Telephone Device for the
Deaf (TDD), Text Telephone (TTY) number, and/or Federal
Information Relay Service (FIRS) number.
2. Content and Form of Application Submission—Required. This

section must identify the required content of an application and
the forms or formats that an applicant must use to submit it. If
any requirements are stated elsewhere because they are
general requirements that apply to multiple programs or funding
opportunities, this section should refer to where those
requirements may be found. This section also should include
required forms or formats as part of the announcement or state
where the applicant may obtain them.
This section should specifically address content and form or

format requirements for:
i. Pre-applications, letters of intent, or white papers required or

encouraged (see Section D.4), including any limitations on the
number of pages or other formatting requirements similar to
those for full applications.
ii. The application as a whole. For all submissions, this would

include any limitations on the number of pages, font size and
typeface, margins, paper size, number of copies, and sequence
or assembly requirements. If electronic submission is permitted
or required, this could include special requirements for
formatting or signatures.
iii. Component pieces of the application (e.g., if all copies of the

application must bear original signatures on the face page or the
program narrative may not exceed 10 pages). This includes any
pieces that may be submitted separately by third parties (e.g.,
references or letters confirming commitments from third parties
that will be contributing a portion of any required cost sharing).
iv. Information that successful applicants must submit after

notification of intent to make a Federal award, but prior to a
Federal award. This could include evidence of compliance with
requirements relating to human subjects or information needed

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to comply with the National Environmental Policy Act (NEPA)

(42 U.S.C. 4321-4370h).
3. Unique entity identifier and System for Award Management

(SAM)—Required.
This paragraph must state clearly that each applicant (unless

the applicant is an individual or Federal awarding agency that is
excepted from those requirements under 2 CFR §25.110(b) or
(c), or has an exception approved by the Federal awarding
agency under 2 CFR §25.110(d)) is required to: (i) Be registered
in SAM before submitting its application; (ii) provide a a valid
unique entity identifier in its application; and (iii) continue to
maintain an active SAM registration with current information at
all times during which it has an active Federal award or an
application or plan under consideration by a Federal awarding
agency. It also must state that the Federal awarding agency
may not make a Federal award to an applicant until the
applicant has complied with all applicable unique entity identifier
and SAM requirements and, if an applicant has not fully
complied with the requirements by the time the Federal
awarding agency is ready to make a Federal award, the Federal
awarding agency may determine that the applicant is not
qualified to receive a Federal award and use that determination
as a basis for making a Federal award to another applicant.
4. Submission Dates and Times—Required. Announcements

must identify due dates and times for all submissions. This
includes not only the full applications but also any preliminary
submissions (e.g., letters of intent, white papers, or pre-
applications). It also includes any other submissions of
information before Federal award that are separate from the full
application. If the funding opportunity is a general
announcement that is open for a period of time with no specific
due dates for applications, this section should say so. Note that
the information on dates that is included in this section also
must appear with other overview information in a location
preceding the full text of the announcement (see §200.203
Notices of funding opportunities of this Part).
Each type of submission should be designated as encouraged

or required and, if required, any deadline date (or dates, if the
Federal awarding agency plans more than one cycle of
application submission, review, and Federal award under the
announcement) should be specified. The announcement must
state (or provide a reference to another document that states):
i. Any deadline in terms of a date and local time. If the due date
falls on a Saturday, Sunday, or Federal holiday, the reporting
package is due the next business day.
ii. What the deadline means (e.g., whether it is the date and

time by which the Federal awarding agency must receive the

application, the date by which the application must be
postmarked, or something else) and how that depends, if at all,
on the submission method (e.g., mail, electronic, or
personal/courier delivery).
iii. The effect of missing a deadline (e.g., whether late

applications are neither reviewed nor considered or are
reviewed and considered under some circumstances).
iv. How the receiving Federal office determines whether an

application or pre-application has been submitted before the
deadline. This includes the form of acceptable proof of mailing
or system-generated documentation of receipt date and time.
This section also may indicate whether, when, and in what form
the applicant will receive an acknowledgement of receipt. This
information should be displayed in ways that will be easy to
understand and use. It can be difficult to extract all needed
information from narrative paragraphs, even when they are well
written. A tabular form for providing a summary of the
information may help applicants for some programs and give
them what effectively could be a checklist to verify the
completeness of their application package before submission.
5. Intergovernmental Review—Required, if applicable. If the

funding opportunity is subject to Executive Order 12372,
“Intergovernmental Review of Federal Programs,” the notice
must say so. In alerting applicants that they must contact their
state's Single Point of Contact (SPOC) to find out about and
comply with the state's process under Executive Order 12372, it
may be useful to inform potential applicants that the names and
addresses of the SPOCs are listed in the Office of Management
and Budget's Web site.
www.whitehouse.gov/omb/grants/spoc.html.
6. Funding Restrictions—Required. Notices must include

information on funding restrictions in order to allow an applicant
to develop an application and budget consistent with program
requirements. Examples are whether construction is an
allowable activity, if there are any limitations on direct costs
such as foreign travel or equipment purchases, and if there are
any limits on indirect costs (or facilities and administrative
costs). Applicants must be advised if Federal awards will not
allow reimbursement of pre-Federal award costs.
7. Other Submission Requirements— Required. This section

must address any other submission requirements not included
in the other paragraphs of this section. This might include the
format of submission, i.e., paper or electronic, for each type of
required submission. Applicants should not be required to
submit in more than one format and this section should indicate
whether they may choose whether to submit applications in hard
200 SUBPART C)
copy or electronically, may submit only in hard copy, or may

submit only electronically.
This section also must indicate where applications (and any pre-
applications) must be submitted if sent by postal mail, electronic
means, or hand-delivery. For postal mail submission, this must
include the name of an office, official, individual or function (e.g.,
application receipt center) and a complete mailing address. For
electronic submission, this must include the URL or email
address; whether a password(s) is required; whether particular
software or other electronic capabilities are required; what to do
in the event of system problems and a point of contact who will
be available in the event the applicant experiences technical
difficulties.1
1With respect to electronic methods for providing information

about funding opportunities or accepting applicants'
submissions of information, each Federal awarding agency is
responsible for compliance with Section 508 of the
Rehabilitation Act of 1973 (29 U.S.C. 794d).
E. Application Review Information
1. Criteria—Required. This section must address the criteria that

the Federal awarding agency will use to evaluate applications.
This includes the merit and other review criteria that evaluators
will use to judge applications, including any statutory, regulatory,
or other preferences (e.g., minority status or Native American
tribal preferences) that will be applied in the review process.
These criteria are distinct from eligibility criteria that are
addressed before an application is accepted for review and any
program policy or other factors that are applied during the
selection process, after the review process is completed. The
intent is to make the application process transparent so
applicants can make informed decisions when preparing their
applications to maximize fairness of the process. The
announcement should clearly describe all criteria, including any
sub-criteria. If criteria vary in importance, the announcement
should specify the relative percentages, weights, or other
means used to distinguish among them. For statutory,
regulatory, or other preferences, the announcement should
provide a detailed explanation of those preferences with an
explicit indication of their effect (e.g., whether they result in
additional points being assigned).
If an applicant's proposed cost sharing will be considered in the

review process (as opposed to being an eligibility criterion
described in Section C.2), the announcement must specifically
address how it will be considered (e.g., to assign a certain
number of additional points to applicants who offer cost sharing,
or to break ties among applications with equivalent scores after
evaluation against all other factors). If cost sharing will not be
considered in the evaluation, the announcement should say so,

so that there is no ambiguity for potential applicants. Vague
statements that cost sharing is encouraged, without clarification
as to what that means, are unhelpful to applicants. It also is
important that the announcement be clear about any restrictions
on the types of cost (e.g., in-kind contributions) that are
acceptable as cost sharing.
2. Review and Selection Process—Required. This section may

vary in the level of detail provided. The announcement must list
any program policy or other factors or elements, other than
merit criteria, that the selecting official may use in selecting
applications for Federal award (e.g., geographical dispersion,
program balance, or diversity). The Federal awarding agency
may also include other appropriate details. For example, this
section may indicate who is responsible for evaluation against
the merit criteria (e.g., peers external to the Federal awarding
agency or Federal awarding agency personnel) and/or who
makes the final selections for Federal awards. If there is a multi-
phase review process (e.g., an external panel advising internal
Federal awarding agency personnel who make final
recommendations to the deciding official), the announcement
may describe the phases. It also may include: the number of
people on an evaluation panel and how it operates, the way
reviewers are selected, reviewer qualifications, and the way that
conflicts of interest are avoided. With respect to electronic
methods for providing information about funding opportunities or
accepting applicants' submissions of information, each Federal
awarding agency is responsible for compliance with Section 508
of the Rehabilitation Act of 1973 (29 U.S.C. 794d).
In addition, if the Federal awarding agency permits applicants to

nominate suggested reviewers of their applications or suggest
those they feel may be inappropriate due to a conflict of interest,
that information should be included in this section.
3. For any Federal award under a notice of funding opportunity,

if the Federal awarding agency anticipates that the total Federal
share will be greater than the simplified acquisition threshold on
any Federal award under a notice of funding opportunity may
include, over the period of performance (see §200.88 Simplified
Acquisition Threshold), this section must also inform applicants:
i. That the Federal awarding agency, prior to making a Federal

award with a total amount of Federal share greater than the
simplified acquisition threshold, is required to review and
consider any information about the applicant that is in the
designated integrity and performance system accessible
through SAM (currently FAPIIS) (see 41 U.S.C. 2313);
ii. That an applicant, at its option, may review information in the

designated integrity and performance systems accessible
through SAM and comment on any information about itself that
200 SUBPART C)
a Federal awarding agency previously entered and is currently

in the designated integrity and performance system accessible
through SAM;
iii. That the Federal awarding agency will consider any

comments by the applicant, in addition to the other information
in the designated integrity and performance system, in making a
judgment about the applicant's integrity, business ethics, and
record of performance under Federal awards when completing
the review of risk posed by applicants as described in §200.205
Federal awarding agency review of risk posed by applicants.
4. Anticipated Announcement and Federal Award Dates—

Optional. This section is intended to provide applicants with
information they can use for planning purposes. If there is a
single application deadline followed by the simultaneous review
of all applications, the Federal awarding agency can include in
this section information about the anticipated dates for
announcing or notifying successful and unsuccessful applicants
and for having Federal awards in place. If applications are
received and evaluated on a “rolling” basis at different times
during an extended period, it may be appropriate to give
applicants an estimate of the time needed to process an
application and notify the applicant of the Federal awarding
agency's decision.
F. Federal Award Administration Information
1. Federal Award Notices—Required. This section must address

what a successful applicant can expect to receive following
selection. If the Federal awarding agency's practice is to provide
a separate notice stating that an application has been selected
before it actually makes the Federal award, this section would
be the place to indicate that the letter is not an authorization to
begin performance (to the extent that it allows charging to
Federal awards of pre-award costs at the non-Federal entity's
own risk). This section should indicate that the notice of Federal
award signed by the grants officer (or equivalent) is the
authorizing document, and whether it is provided through postal
mail or by electronic means and to whom. It also may address
the timing, form, and content of notifications to unsuccessful
applicants. See also §200.210 Information contained in a
Federal award.
2. Administrative and National Policy Requirements—Required.

This section must identify the usual administrative and national
policy requirements the Federal awarding agency's Federal
awards may include. Providing this information lets a potential
applicant identify any requirements with which it would have
difficulty complying if its application is successful. In those
cases, early notification about the requirements allows the
potential applicant to decide not to apply or to take needed
actions before receiving the Federal award. The announcement

need not include all of the terms and conditions of the Federal
award, but may refer to a document (with information about how
to obtain it) or Internet site where applicants can see the terms
and conditions. If this funding opportunity will lead to Federal
awards with some special terms and conditions that differ from
the Federal awarding agency's usual (sometimes called
“general”) terms and conditions, this section should highlight
those special terms and conditions. Doing so will alert
applicants that have received Federal awards from the Federal
awarding agency previously and might not otherwise expect
different terms and conditions. For the same reason, the
announcement should inform potential applicants about special
requirements that could apply to particular Federal awards after
the review of applications and other information, based on the
particular circumstances of the effort to be supported (e.g., if
human subjects were to be involved or if some situations may
justify special terms on intellectual property, data sharing or
security requirements).
3. Reporting—Required. This section must include general

information about the type (e.g., financial or performance),
frequency, and means of submission (paper or electronic) of
post-Federal award reporting requirements. Highlight any
special reporting requirements for Federal awards under this
funding opportunity that differ (e.g., by report type, frequency,
form/format, or circumstances for use) from what the Federal
awarding agency's Federal awards usually require. Federal
awarding agencies must also describe in this section all relevant
requirements such as those at 2 CFR 180.335 and 2 CFR
180.350.
If the Federal share of any Federal award may include more

than $500,000 over the period of performance, this section must
inform potential applicants about the post award reporting
requirements reflected in Appendix XII—Award Term and
Condition for Recipient Integrity and Performance Matters.
G. Federal Awarding Agency Contact(s)—Required
The announcement must give potential applicants a point(s) of

contact for answering questions or helping with problems while
the funding opportunity is open. The intent of this requirement is
to be as helpful as possible to potential applicants, so the
Federal awarding agency should consider approaches such as
giving:
i. Points of contact who may be reached in multiple ways (e.g.,

by telephone, FAX, and/or email, as well as regular mail).
ii. A fax or email address that multiple people access, so that

someone will respond even if others are unexpectedly absent
during critical periods.
200 SUBPART C)
iii. Different contacts for distinct kinds of help (e.g., one for
questions of programmatic content and a second for
administrative questions).
H. Other Information—Optional
This section may include any additional information that will

assist a potential applicant. For example, the section might:
i. Indicate whether this is a new program or a one-time initiative.
ii. Mention related programs or other upcoming or ongoing

Federal awarding agency funding opportunities for similar
activities.
iii. Include current Internet addresses for Federal awarding

agency Web sites that may be useful to an applicant in
understanding the program.
iv. Alert applicants to the need to identify proprietary information

and inform them about the way the Federal awarding agency
will handle it.
v. Include certain routine notices to applicants (e.g., that the

Federal Government is not obligated to make any Federal
award as a result of the announcement or that only grants
officers can bind the Federal Government to the expenditure of
funds).
200 SUBPART C)
LESSON 3
MERIT REVIEW PROCESS
Lesson Objective
3.3.1 Understand the merit review process
3.1 §200.204 FEDERAL AWARDING AGENCY REVIEW OF MERIT

PROPOSALS
Federal Grant Award Process, Step Three: Conduct Merit Review of Applications
LESSON 3 | MERIT REVIEW PROCESS
§200.204 Federal awarding agency review of merit of

proposals.
For competitive grants or cooperative agreements, unless

prohibited by Federal statute, the Federal awarding agency
must design and execute a merit review process for
applications. This process must be described or incorporated by
reference in the applicable funding opportunity (see Appendix I
to this part, Full text of the Funding Opportunity.) See also
§200.203 Notices of funding opportunities.
Federal agencies are required to develop and implement a merit review process for competitive
grant awards. The Uniform Guidance provides agencies with flexibility in developing merit-based
selection criteria. The selection criteria must be published in the announcement of funding
opportunity to fully inform applicants of the selection process. Awarding agencies should clearly
describe all criteria, including any subcriteria, used in the award selection process. Additionally, the
agency must specify the relative percentages or weights given to each criterion.
Award selection, however, does not need to be based solely on merit. Agencies must identify
additional criteria that is used in awards selection. Some examples include geographic dispersion,
program balance, or diversity. Though not required, agencies may indicate the individual(s)
responsible for evaluating applications and the official responsible for final selection.
Discussion
How will 2 CFR 200.204 Federal Awarding Agency Review of

Merit Proposals affect your entity?
200 SUBPART C)
Example: Department of Commerce Merit Review Policy 1
It is the policy of [the Department of Commerce] DOC to seek

full and open competition for award of discretionary funds.
Moreover, DOC financial assistance must be awarded through a
merit-based review and selection process whenever possible.
This [policy] prescribes the standards and procedures to be
used by operating unit officials and grants officers for reviewing,
selecting, approving, and notifying applicants of funding
decisions.
Review Standards
1. Applications. All applications for financial assistance should

receive a fair, equitable, and objective review.
a. The following are minimum general requirements that must
be met in order for any application to be processed for funding
under DOC financial assistance programs:
(1) Legislative authority to perform the work with financial
assistance;
(2) Funding availability;
(3) Complete application package; and
(4) Scope of work that is consistent with DOC’s mission.
b. Applications should undergo an initial screening for

conformance with the minimum general requirements and any
mandatory technical and administrative requirements stated in
the program’s regulations and FFO. The Program Office must
document and maintain a record of reason(s) if any application
is determined to be incomplete.
c. Applications that meet the requirements of the initial

screening are then subject to the objective merit review as
provided in B.4., below.
2. Nondiscretionary Funds. All awards made with
nondiscretionary funds shall be subject to an objective merit
review by at least one reviewer who is professionally and
technically qualified to conduct the review. This review is limited
to technical and/or cost matters.
3. Discretionary Funds. Except as provided below, all awards
made with discretionary funds shall be subject to an objective
merit review by a group of at least three professionally and
technically qualified reviewers. This review is limited to technical
and/or cost matters and is separate from any programmatic
review of program and policy factors, which may be considered
in making a selection or non-selection decision.
4. Merit Reviews of Competitive and Noncompetitive Awards.
1
United States Government of Commerce.Grants Policy.Last modified February 9, 2018
LESSON 3 | MERIT REVIEW PROCESS
a. Merit Review of Competitive Awards:

(1) An objective merit review of financial assistance applications
is advisory and does not replace the authority of the program
official responsible for deciding whether to recommend funding
for an award.
(2) The merit review criteria for new competitive awards and
competitive amendments for renewal must be in accordance
with evaluation criteria set forth in the applicable program
regulations and FFO. The merit review procedures must set
forth the relationship between the reviewing individuals, or the
review committees or groups, and the official who has the final
decision-making authority. In defining this relationship, the
program must set out, at a minimum, the decision-making and
documentation processes to be followed by the authorized
official responsible for selection. This should cover the
procedures to be used when an adverse recommendation has
been received through the objective merit review process or
when selection for funding recommendations may be made out
of rank order or when selection for funding differs from the
recommendations resulting from the merit review process. For
example, published funding priorities may affect final selection
for funding.
200 SUBPART C)
LESSON 4
PRE-AWARD RISK ASSESSMENT
Lesson Objective
3.4.1 Explain the pre-award risk assessment process
Federal Grant Award Process, Step Four: Complete Risk Assessment
LESSON 4 | PRE-AWARD RISK ASSESSMENT
4.1 §200.205 FEDERAL AWARDING AGENCY REVIEW OF RISK

POSED BY APPLICANTS
Pre-Award Risk Assessment
200 SUBPART C)
§200.205 Federal awarding agency review of risk posed by

applicants.
(a) Review of OMB-designated repositories of governmentwide

data.
(1) Prior to making a Federal award, the Federal awarding

agency is required by 31 U.S.C. 3321 and 41 U.S.C. 2313 note
to review information available through any OMB-designated
repositories of governmentwide eligibility qualification or
financial integrity information as appropriate. See also
suspension and debarment requirements at 2 CFR part 180 as
well as individual Federal agency suspension and debarment
regulations in title 2 of the Code of Federal Regulations.
(2) In accordance 41 U.S.C. 2313, the Federal awarding agency

is required to review the publicly available information in the
OMB-designated integrity and performance system accessible
through SAM (currently the Federal Awardee Performance and
Integrity Information System (FAPIIS)) prior to making a Federal
award where the Federal share is expected to exceed the
simplified acquisition threshold, defined in 41 U.S.C. 134, over
the period of performance. At a minimum, the information in the
system for a prior Federal award recipient must demonstrate a
satisfactory record of executing programs or activities under
Federal grants, cooperative agreements, or procurement
awards; and integrity and business ethics. The Federal
awarding agency may make a Federal award to a recipient who
does not fully meet these standards, if it is determined that the
information is not relevant to the current Federal award under
consideration or there are specific conditions that can
appropriately mitigate the effects of the non-Federal entity's risk
in accordance with §200.207 Specific conditions.
(b) In addition, for competitive grants or cooperative

agreements, the Federal awarding agency must have in place a
framework for evaluating the risks posed by applicants before
they receive Federal awards. This evaluation may incorporate
results of the evaluation of the applicant's eligibility or the quality
of its application. If the Federal awarding agency determines
that a Federal award will be made, special conditions that
correspond to the degree of risk assessed may be applied to the
Federal award. Criteria to be evaluated must be described in the
announcement of funding opportunity described in §200.203
Notices of funding opportunities.
(c) In evaluating risks posed by applicants, the Federal

awarding agency may use a risk-based approach and may
consider any items such as the following:
(1) Financial stability;
(2) Quality of management systems and ability to meet the

management standards prescribed in this part;
(3) History of performance. The applicant's record in managing

Federal awards, if it is a prior recipient of Federal awards,
including timeliness of compliance with applicable reporting
requirements, conformance to the terms and conditions of
previous Federal awards, and if applicable, the extent to which
any previously awarded amounts will be expended prior to
future awards;
(4) Reports and findings from audits performed under Subpart

F—Audit Requirements of this part or the reports and findings of
any other available audits; and
(5) The applicant's ability to effectively implement statutory,

regulatory, or other requirements imposed on non-Federal
entities.
(d) In addition to this review, the Federal awarding agency must

comply with the guidelines on governmentwide suspension and
debarment in 2 CFR part 180, and must require non-Federal
entities to comply with these provisions. These provisions
restrict Federal awards, subawards and contracts with certain
parties that are debarred, suspended or otherwise excluded
from or ineligible for participation in Federal programs or
activities.
The Uniform Guidance requires federal awarding agencies to conduct a financial risk assessment of
recipients before making an award.1 2 CFR 200.205 states that agencies are required by law to
verify recipient eligibility by using the Do Not Pay List. This database contains information from
multiple sources including the Death Master File and SAM.gov.
This section also reiterates existing regulations found in 2 CFR 180 that require agencies to comply
with suspension and debarment policies. Under this regulation, non-federal entities must also verify
subrecipient and contractor eligibility through the Exclusions Extract database on SAM.gov.
Additionally, for awards expected to exceed the Simplified Acquisition Threshold, federal agencies
must check the FAPIIS.gov database.
Under 2 CFR 200.205, federal awarding agencies must also develop and implement a framework
for evaluating risk posed by applicants before making an award. The language in 2 CFR 200.205
provides flexibility to agencies to design a risk assessment framework that best meets the agency's
needs. For example, agencies with long histories and experiences with specific recipients may
choose to review program files or prior audit reports. This review may be conducted in lieu of an
exhaustive analysis.
1
Under 2 CFR 200.33, pass-through entities are required to conduct a risk assessment on subrecipients; however, pass-
through entities are not required to conduct the risk assessment before making a subaward.
200 SUBPART C)
The following list identifies some of the recommended elements for the pre-award risk assessment.
Awarding agencies may examine the recipient's:
 Financial stability
 Management systems
 History of performance
 Prior audits
 Ability to comply with regulations
Federal Grant Award Process, Step Five: Update FAPIIS, If Necessary
Note that each federal awarding agency will be required to report in FAPIIS any finding that a non-
federal entity is not qualified to receive an award, if the award is over the simplified acquisition
threshold, and if the finding is based on criteria related to the non-federal entity's integrity or prior
performance under a federal award.
Discussion
 What additional factors should federal awarding agencies

examine?
 How should non-federal entities prepare for a risk
assessment?
200 SUBPART C)
LESSON 5
APPLICATION FORMS
Lesson Objective
3.5.1 Determine which forms may be required for award applications.
5.1 §200.206 STANDARD APPLICATION REQUIREMENTS

§200.206 Standard application requirements.
(a) Paperwork clearances. The Federal awarding agency may

only use application information collections approved by OMB
under the Paperwork Reduction Act of 1995 and OMB's
implementing regulations in 5 CFR part 1320, Controlling
Paperwork Burdens on the Public. Consistent with these
requirements, OMB will authorize additional information
collections only on a limited basis.
(b) If applicable, the Federal awarding agency may inform

applicants and recipients that they do not need to provide
certain information otherwise required by the relevant
information collection.
Discussion
How do you deal with gathering (as a federal agency or pass-

through entity) or providing (as an applicant) information that
does not fit on the form?
LESSON 5 | APPLICATION FORMS
200 SUBPART C)
LESSON 6
SPECIFIC CONDITIONS
Lesson Objective
3.6.1 Identify the requirements an agency may place on a recipient as a result of the risk
assessment
After the Risk Assessment
LESSON 6 | SPECIFIC CONDITIONS
6.1 §200.207 SPECIFIC CONDITIONS
Federal Grant Award Process, Step Six: Apply Specific Conditions
200 SUBPART C)
§200.207 Specific conditions.
(a) The Federal awarding agency or pass-through entity may

impose additional specific award conditions as needed, in
accordance with paragraphs (b) and (c) of this section, under
the following circumstances:
(1) Based on the criteria set forth in §200.205 Federal awarding

agency review of risk posed by applicants;
(2) When an applicant or recipient has a history of failure to

comply with the general or specific terms and conditions of a
Federal award;
(3) When an applicant or recipient fails to meet expected

performance goals as described in §200.210 Information
contained in a Federal award; or
(4) When an applicant or recipient is not otherwise responsible.
(b) These additional Federal award conditions may include

items such as the following:
(1) Requiring payments as reimbursements rather than advance

payments;
(2) Withholding authority to proceed to the next phase until

receipt of evidence of acceptable performance within a given
period of performance;
(3) Requiring additional, more detailed financial reports;
(4) Requiring additional project monitoring;
(5) Requiring the non-Federal entity to obtain technical or

management assistance; or
(6) Establishing additional prior approvals.
(c) The Federal awarding agency or pass-through entity must

notify the applicant or non-Federal entity as to:
(1) The nature of the additional requirements;
(2) The reason why the additional requirements are being

imposed;
(3) The nature of the action needed to remove the additional

requirement, if applicable;
(4) The time allowed for completing the actions if applicable,

and
LESSON 6 | SPECIFIC CONDITIONS
(5) The method for requesting reconsideration of the additional

requirements imposed.
(d) Any specific conditions must be promptly removed once the

conditions that prompted them have been corrected.
Specific Award Conditions
Federal awarding agencies should use the pre-award risk assessment to evaluate the potential risk
to federal funds. Federal awarding agencies may make an award to an applicant that is considered
“high risk,” however, agencies should apply specific conditions to the award that will mitigate the
risk. 2 CFR 200.207 identifies some of the specific conditions available to federal awarding
agencies and describes the procedures for applying them. Any special condition placed on an
award should be included in the award terms and conditions. Additionally, special conditions may
be placed on an award when problems arise during the post-award phase. Pass-through entities
may also apply special conditions on subawards.
Discussion
 How do you communicate additional conditions with an

awardee?
 If you are an awardee, do you ask for technical assistance?
200 SUBPART C)
LESSON 7
CERTIFICATIONS AND
REPRESENTATIONS
Lesson Objective
3.7.1 Describe the purpose and use of certifications and representations
7.1 §200.208 CERTIFICATIONS AND REPRESENTATIONS

§200.208 Certifications and representations.
Unless prohibited by Federal statutes or regulations, each

Federal awarding agency or pass-through entity is authorized to
require the non-Federal entity to submit certifications and
representations required by Federal statutes, or regulations on
an annual basis. Submission may be required more frequently if
the non-Federal entity fails to meet a requirement of a Federal
award.
2 CFR 200.208 allows federal awarding agencies and pass-through entities to require recipients to
submit compliance certifications and representations on an annual basis. If a recipient has failed to
comply with a specific requirement of the award, then the awarding agency or pass-through entity
can require the recipient to submit certifications and representations more frequently.
By signing and submitting a certification and

representation, the recipient guarantees that all
submitted information is correct and that the entity
is in compliance with award regulations and
requirements. The recipient also acknowledges
that submitting falsified information or failing to
comply with the award may result in legal
consequences.
Certifications and Representations
LESSON 7 | CERTIFICATIONS AND REPRESENTATIONS
Discussion
What consequences have you seen agencies apply related to

certifications and representations?
7.2 §200.209 PRE-AWARD COSTS

§200.209 Pre-award costs.
For requirements on costs incurred by the applicant prior to the

start date of the period of performance of the Federal award,
see §200.458 Pre-award costs.
200 SUBPART C)
LESSON 8
FEDERAL AWARD DOCUMENT
Lesson Objective
3.8.1 Identify and explain the required elements of a federal award document.
8.1 §200.210 INFORMATION CONTAINED IN A FEDERAL AWARD
Grant Award Notification Document
LESSON 8 | FEDERAL AWARD DOCUMENT
§200.210 Information contained in a Federal award.
A Federal award must include the following information:
(a) General Federal Award Information. The Federal awarding

agency must include the following general Federal award
information in each Federal award:
(1) Recipient name (which must match the name associated

with its unique entity identifier as defined at 2 CFR 25.315);
(2) Recipient's unique entity identifier;
(3) Unique Federal Award Identification Number (FAIN);
(4) Federal Award Date (see §200.39 Federal award date);
(5) Period of Performance Start and End Date;
(6) Amount of Federal Funds Obligated by this action;
(7) Total Amount of Federal Funds Obligated;
(8) Total Amount of the Federal Award;
(9) Budget Approved by the Federal Awarding Agency;
(10) Total Approved Cost Sharing or Matching, where

applicable;
(11) Federal award project description, (to comply with statutory

requirements (e.g., FFATA));
(12) Name of Federal awarding agency and contact information

for awarding official,
(13) Assistance Listings [Formerly known as CFDA] Number

and Name;
(14) Identification of whether the award is R&D; and
(15) Indirect cost rate for the Federal award (including if the de
minimis rate is charged per §200.414 Indirect (F&A) costs).
(b) General Terms and Conditions (1) Federal awarding

agencies must incorporate the following general terms and
conditions either in the Federal award or by reference, as
applicable:
(i) Administrative requirements implemented by the Federal

awarding agency as specified in this part.
(ii) National policy requirements. These include statutory,
200 SUBPART C)
executive order, other Presidential directive, or regulatory

requirements that apply by specific reference and are not
program-specific. See §200.300 Statutory and national policy
requirements.
(iii) Recipient integrity and performance matters. If the total

Federal share of the Federal award may include more than
$500,000 over the period of performance, the Federal awarding
agency must include the term and condition available in
Appendix XII—Award Term and Condition for Recipient Integrity
and Performance Matters. See also §200.113 Mandatory
disclosures.
(2) The Federal award must include wording to incorporate, by

reference, the applicable set of general terms and conditions.
The reference must be to the Web site at which the Federal
awarding agency maintains the general terms and conditions.
(3) If a non-Federal entity requests a copy of the full text of the

general terms and conditions, the Federal awarding agency
must provide it.
(4) Wherever the general terms and conditions are publicly

available, the Federal awarding agency must maintain an
archive of previous versions of the general terms and
conditions, with effective dates, for use by the non-Federal
entity, auditors, or others.
(c) Federal Awarding Agency, Program, or Federal Award

Specific Terms and Conditions. The Federal awarding agency
may include with each Federal award any terms and conditions
necessary to communicate requirements that are in addition to
the requirements outlined in the Federal awarding agency's
general terms and conditions. Whenever practicable, these
specific terms and conditions also should be shared on a public
Web site and in notices of funding opportunities (as outlined in
§200.203 Notices of funding opportunities) in addition to being
included in a Federal award. See also §200.206 Standard
application requirements.
(d) Federal Award Performance Goals. The Federal awarding

agency must include in the Federal award an indication of the
timing and scope of expected performance by the non-Federal
entity as related to the outcomes intended to be achieved by the
program. In some instances (e.g., discretionary research
awards), this may be limited to the requirement to submit
technical performance reports (to be evaluated in accordance
with Federal awarding agency policy). Where appropriate, the
Federal award may include specific performance goals,
indicators, milestones, or expected outcomes (such as outputs,
or services performed or public impacts of any of these) with an
expected timeline for accomplishment. Reporting requirements
must be clearly articulated such that, where appropriate,

performance during the execution of the Federal award has a
standard against which non-Federal entity performance can be
measured. The Federal awarding agency may include program-
specific requirements, as applicable. These requirements
should be aligned with agency strategic goals, strategic
objectives or performance goals that are relevant to the
program. See also OMB Circular A-11, Preparation, Submission
and Execution of the Budget Part 6 for definitions of strategic
objectives and performance goals.
(e) Any other information required by the Federal awarding

agency.
The Uniform Guidance creates a standard governmentwide requirement for information contained
in a federal award. This uniform set of data elements is designed to improve the ability of non-
federal recipients to understand and manage grant awards. Pass-through entities are also required
to incorporate the standard data elements into subawards.
Federal awarding agencies and pass-through entities are required to identify the Federal Award
Identification Number (FAIN) in the grant award. The FAIN is a unique identifier for every federal
grant award. As of October 1, 2013 federal agencies are required to assign a FAIN to each grant
project. The FAIN must be used in all award related documents. Pass-through entities are also
required to use the assigned FAIN on all subawards and ensure subrecipient compliance with the
requirement. The use of the FAIN is intended to enhance data quality on www.USASpending.gov
by allowing the public to more easily track specific government awards and spending. Grant
recipients that have not received a FAIN from an awarding agency should contact a program officer.
The Uniform Guidance also requires federal agencies to develop performance goals to measure
project performance. This requirement is designed to ensure non-federal entities are using federal
funds efficiently and effectively. The Uniform Guidance provides for special consideration for
research award recipients by allowing researchers to submit technical performance reports.
The requirement to reference Appendix XII of 2 CFR 200 for awards expected to exceed $500,000
over the life of the award, is new as of July 22, 2015. The appendix is reproduced below.
200 SUBPART C)
Appendix XII of 2 CFR 200—Award Term and Condition for

Recipient Integrity and Performance Matters
A. Reporting of Matters Related to Recipient Integrity and

Performance
1. General Reporting Requirement
If the total value of your currently active grants, cooperative

agreements, and procurement contracts from all Federal
awarding agencies exceeds $10,000,000 for any period of time
during the period of performance of this Federal award, then
you as the recipient during that period of time must maintain the
currency of information reported to the System for Award
Management (SAM) that is made available in the designated
integrity and performance system (currently the Federal
Awardee Performance and Integrity Information System
(FAPIIS)) about civil, criminal, or administrative proceedings
described in paragraph 2 of this award term and condition. This
is a statutory requirement under section 872 of Public Law 110-
417, as amended (41 U.S.C. 2313). As required by section 3010
of Public Law 111-212, all information posted in the designated
integrity and performance system on or after April 15, 2011,
except past performance reviews required for Federal
procurement contracts, will be publicly available.
2. Proceedings About Which You Must Report
Submit the information required about each proceeding that:
a. Is in connection with the award or performance of a grant,

cooperative agreement, or procurement contract from the
Federal Government;
b. Reached its final disposition during the most recent five year
period; and
c. Is one of the following:
(1) A criminal proceeding that resulted in a conviction, as

defined in paragraph 5 of this award term and condition;
(2) A civil proceeding that resulted in a finding of fault and

liability and payment of a monetary fine, penalty,
reimbursement, restitution, or damages of $5,000 or more;
(3) An administrative proceeding, as defined in paragraph 5. of

this award term and condition, that resulted in a finding of fault
and liability and your payment of either a monetary fine or
penalty of $5,000 or more or reimbursement, restitution, or
damages in excess of $100,000; or
(4) Any other criminal, civil, or administrative proceeding if:
(i) It could have led to an outcome described in paragraph

2.c.(1), (2), or (3) of this award term and condition;
(ii) It had a different disposition arrived at by consent or

compromise with an acknowledgment of fault on your part; and
(iii) The requirement in this award term and condition to disclose

information about the proceeding does not conflict with
applicable laws and regulations.
3. Reporting Procedures
Enter in the SAM Entity Management area the information that

SAM requires about each proceeding described in paragraph 2
of this award term and condition. You do not need to submit the
information a second time under assistance awards that you
received if you already provided the information through SAM
because you were required to do so under Federal procurement
contracts that you were awarded.
4. Reporting Frequency
During any period of time when you are subject to the

requirement in paragraph 1 of this award term and condition,
you must report proceedings information through SAM for the
most recent five year period, either to report new information
about any proceeding(s) that you have not reported previously
or affirm that there is no new information to report. Recipients
that have Federal contract, grant, and cooperative agreement
awards with a cumulative total value greater than $10,000,000
must disclose semiannually any information about the criminal,
civil, and administrative proceedings.
5. Definitions
For purposes of this award term and condition:
a. Administrative proceeding means a non-judicial process that

is adjudicatory in nature in order to make a determination of
fault or liability (e.g., Securities and Exchange Commission
Administrative proceedings, Civilian Board of Contract Appeals
proceedings, and Armed Services Board of Contract Appeals
proceedings). This includes proceedings at the Federal and
State level but only in connection with performance of a Federal
contract or grant. It does not include audits, site visits, corrective
plans, or inspection of deliverables.
b. Conviction, for purposes of this award term and condition,

means a judgment or conviction of a criminal offense by any
court of competent jurisdiction, whether entered upon a verdict
or a plea, and includes a conviction entered upon a plea of nolo
200 SUBPART C)
contendere.
c. Total value of currently active grants, cooperative

agreements, and procurement contracts includes—
(1) Only the Federal share of the funding under any Federal
award with a recipient cost share or match; and
(2) The value of all expected funding increments under a

Federal award and options, even if not yet exercised.
B. [Reserved]
Appendix XII to 2 CFR 200 explains the FAPIIS reporting requirements for non-federal entities.
Appendix XII to 2 CFR 200 only applies to non-federal entities that have more than $10 million in
total active grants, cooperative agreements, and procurement contracts at any given time.
Those non-federal entities must:
 Report to FAPIIS about certain civil, criminal, or administrative proceedings in connection to a
federal award within the last five years
 On a semiannual basis, either disclose any new information about any proceedings not
previously reported or affirm that there is no new information to report
Discussion
Poll: What provision in 2 CFR 200 is designed to ensure that

non-federal entities are using federal funds efficiently and
effectively?
A Requirement for federal agencies to develop performance
goals to measure project performance.
B Requirement for uniform set of data elements in grant
awards.
C Requirement for federal agencies to assign a Federal Award
Identification Number (FAIN) to each grant award.
Poll: What provision in 2 CFR 200 is intended to enhance data
quality by allowing the public to more easily track specific
government awards and spending?
A Requirement for federal agencies to develop performance
goals to measure project performance.
B Requirement for uniform set of data elements in grant
awards.
C Requirement for federal agencies to assign a Federal Award
200 SUBPART C)
LESSON 9
INFORMATION THAT BECOMES PUBLIC
Lesson Objective
3.9.1 Identify the information about an award that becomes public
Public Information: Access to Federal Award Notification; Reporting a Non-Qualified Determination; and Suspension or Debarment
LESSON 9 | INFORMATION THAT BECOMES PUBLIC
9.1 §200.211 PUBLIC ACCESS TO FEDERAL AWARD NOTIFICATION

§200.211 Public access to Federal award information.
(a) In accordance with statutory requirements for Federal

spending transparency (e.g., FFATA), except as noted in this
section, for applicable Federal awards the Federal awarding
agency must announce all Federal awards publicly and publish
the required information on a publicly available OMB-designated
governmentwide Web site (at time of publication,
www.USAspending.gov).
(b) All information posted in the designated integrity and

performance system accessible through SAM (currently FAPIIS)
on or after April 15, 2011 will be publicly available after a waiting
period of 14 calendar days, except for:
(1) Past performance reviews required by Federal Government

contractors in accordance with the Federal Acquisition
Regulation (FAR) 42.15;
(2) Information that was entered prior to April 15, 2011; or
(3) Information that is withdrawn during the 14-calendar day

waiting period by the Federal Government official.
(c) Nothing in this section may be construed as requiring the

publication of information otherwise exempt under the Freedom
of Information Act (5 U.S.C 552), or controlled unclassified
information pursuant to Executive Order 13556.
Refer to Website
The Digital Accountability and Transparency Act (DATA Act)

affects this provision. The DATA Act requires the publication of
all federal spending at http://www.USASpending.gov.
Additionally, the Duncan Hunter National Defense Authorization Act for fiscal year 2009 required
the creation of a publicly available database for award performance information. The Federal
Awardee Performance and Integrity Information System (FAPIIS) is that database.
200 SUBPART C)
9.2 §200.212 REPORTING A DETERMINATION THAT A NON-FEDERAL

ENTITY IS NOT QUALIFIED FOR A FEDERAL AWARD
§200.212 Reporting a determination that a non-Federal
entity is not qualified for a Federal award.
(a) If a Federal awarding agency does not make a Federal

award to a non-Federal entity because the official determines
that the non-Federal entity does not meet either or both of the
minimum qualification standards as described in §200.205,
Federal awarding agency review of risk posed by applicants,
paragraph (a)(2), the Federal awarding agency must report that
determination to the designated integrity and performance
system accessible through SAM (currently FAPIIS), only if all of
the following apply:
(1) The only basis for the determination described in paragraph

(a) of this section is the non-Federal entity's prior record of
executing programs or activities under Federal awards or its
record of integrity and business ethics, as described in
§200.205 Federal awarding agency review of risk posed by
applicants, paragraph (a)(2) (i.e., the entity was determined to
be qualified based on all factors other than those two
standards), and
(2) The total Federal share of the Federal award that otherwise
would be made to the non-Federal entity is expected to exceed
the simplified acquisition threshold over the period of
performance.
(b) The Federal awarding agency is not required to report a

determination that a non-Federal entity is not qualified for a
Federal award if they make the Federal award to the non-
Federal entity and includes specific award terms and conditions,
as described in §200.207 Specific conditions.
(c) If a Federal awarding agency reports a determination that a

non-Federal entity is not qualified for a Federal award, as
described in paragraph (a) of this section, the Federal awarding
agency also must notify the non-Federal entity that—
(1) The determination was made and reported to the designated

integrity and performance system accessible through SAM, and
include with the notification an explanation of the basis for the
determination;
(2) The information will be kept in the system for a period of five
years from the date of the determination, as required by section
872 of Public Law 110-417, as amended (41 U.S.C. 2313), then
archived;
(3) Each Federal awarding agency that considers making a
Federal award to the non-Federal entity during that five year

period must consider that information in judging whether the
non-Federal entity is qualified to receive the Federal award
when the total Federal share of the Federal award is expected
to include an amount of Federal funding in excess of the
simplified acquisition threshold over the period of performance;
(4) The non-Federal entity may go to the awardee integrity and

performance portal accessible through SAM (currently the
Contractor Performance Assessment Reporting System
(CPARS)) and comment on any information the system contains
about the non-Federal entity itself; and
(5) Federal awarding agencies will consider that non-Federal

entity's comments in determining whether the non-Federal entity
is qualified for a future Federal award.
(d) If a Federal awarding agency enters information into the

through SAM about a determination that a non-Federal entity is
not qualified for a Federal award and subsequently:
(1) Learns that any of that information is erroneous, the Federal

awarding agency must correct the information in the system
within three business days;
(2) Obtains an update to that information that could be helpful to

other Federal awarding agencies, the Federal awarding agency
is strongly encouraged to amend the information in the system
to incorporate the update in a timely way.
(e) Federal awarding agencies shall not post any information

that will be made publicly available in the non-public segment of
designated integrity and performance system that is covered by
a disclosure exemption under the Freedom of Information Act. If
the recipient asserts within seven calendar days to the Federal
awarding agency that posted the information that some or all of
the information made publicly available is covered by a
disclosure exemption under the Freedom of Information Act, the
Federal awarding agency that posted the information must
remove the posting within seven calendar days of receiving the
assertion. Prior to reposting the releasable information, the
Federal awarding agency must resolve the issue in accordance
with the agency's Freedom of Information Act procedures.
Section 872 of the 2009 Duncan Hunter National Defense Authorization Act called for the creation
of a data system that would report on the integrity and performance of contractors and grant
recipients. The General Services Administration (GSA) established the Federal Awardee
Performance and Integrity System (FAPIIS) to track misconduct and performance issues by non-
federal entities.
200 SUBPART C)
FAPIIS identifies:
 Criminal, civil, and administrative proceedings in connection with federal awards
 Suspensions and debarments
 Administrative agreements
 Nonresponsibility determinations
 Awards terminated for fault
 Contractor past performance evaluations
 Defective pricing determinations
When launched in 2010, FAPIIS originally contained only information pertaining to federal contracts.
In July 2015, the Office of Management (OMB) released the final rule to implement FAPIIS for
federal grant awards. OMB amended 2 CFR 200 to incorporate FAPIIS requirements. As of January
1, 2016, federal awarding agencies must comply with the new requirements.
2 CFR 200.205 requires federal awarding agencies to conduct a pre-award risk assessment before
making an award. For all awards over the simplified acquisition threshold, federal awarding
agencies are required to review FAPIIS to evaluate an applicant’s qualifications.
Based on the risk assessment, federal awarding agencies may determine an applicant is “not
qualified” to receive a specific award. When a federal awarding agency makes this determination, 2
CFR 200.212(a) requires the agency to report its decision to FAPIIS if
 The award would have exceed the simplified acquisition threshold, and
 The “not qualified” determination is based on the applicant’s prior record of executing federal
awards or its record of integrity and business ethics
2 CFR 200.212(c) requires federal awarding agencies to notify the applicant when the agency
reports a "not qualified" determination to FAPIIS. The notification must:
 Indicate that the determination was made and reported to FAPIIS
 Provide the reasoning for the determination
 Explain that the determination will be publicly available on FAPIIS for five years from the date of
the determination
 Inform that applicant that other federal awarding agencies must consider the determination
before making an award
 Advise the applicant of the opportunity to respond to the determination through the System for
Award Management (SAM) and that the response will be considered by federal awarding
agencies in future award decisions.
It is important to note that if an applicant is determined to be “not qualified” for one federal award, it
does not mean it will be denied funding for all other awards. The “not qualified” determination is
award-specific.
Under the FAPIIS requirements, federal awarding agencies are also required to:
 Include Appendix XII to 2 CFR 200 in the award terms and conditions for any award over
$500,000
 Report to FAPIIS information relating to the termination of a grant award due to the non-federal
entity’s material failure to comply with the award terms and conditions
 Report to FAPIIS information about any administrative agreement with a non-federal entity to
resolve a suspension or debarment proceeding
 Establish a three-day time period for suspending and debarring officials to report to FAPIIS
about administrative agreements
9.3 §200.213 SUSPENSION AND DEBARMENT

§200.213 Suspension and debarment.
Non-federal entities and contractors are subject to the non-

procurement debarment and suspension regulations
implementing Executive Orders 12549 and 12689, 2 CFR part
180. These regulations restrict awards, subawards, and
contracts with certain parties that are debarred, suspended, or
otherwise excluded from or ineligible for participation in Federal
assistance programs or activities.
2 CFR 200.213 reiterates the responsibilities of federal awarding agencies, non-federal entities, and
contractors to adhere to suspension and debarment requirements. Federal funds cannot be
awarded to a non-federal entity or contractor that has been suspended or debarred. Non-federal
entities may verify the eligibility of a contractor or subaward recipient by reviewing the Exclusions
Extract on http://www.SAM.gov. Federal awarding agencies must also verify a recipient's eligibility
by reviewing the Do Not Pay List.
Discussion
What do you need to be cognizant of, given that this information

will be made public?
200 SUBPART C)
LESSON 10
REMEDIES FOR NONCOMPLIANCE
Lesson Objective
3.10.1 Identify available options to remedy noncompliance
10.1 §200.338 REMEDIES FOR NONCOMPLIANCE

§200.338 Remedies for noncompliance.
If a non-Federal entity fails to comply with Federal statutes,

regulations or the terms and conditions of a Federal award, the
Federal awarding agency or pass-through entity may impose
additional conditions, as described in §200.207 Specific
conditions. If the Federal awarding agency or pass-through
entity determines that noncompliance cannot be remedied by
imposing additional conditions, the Federal awarding agency or
pass-through entity may take one or more of the following
actions, as appropriate in the circumstances:
(a) Temporarily withhold cash payments pending correction of

the deficiency by the non-Federal entity or more severe
enforcement action by the Federal awarding agency or pass-
through entity.
(b) Disallow (that is, deny both use of funds and any applicable
matching credit for) all or part of the cost of the activity or action
not in compliance.
(c) Wholly or partly suspend or terminate the Federal award.
(d) Initiate suspension or debarment proceedings as authorized

under 2 CFR part 180 and Federal awarding agency regulations
(or in the case of a pass-through entity, recommend such a
proceeding be initiated by a Federal awarding agency).
(e) Withhold further Federal awards for the project or program.
(f) Take other remedies that may be legally available.
LESSON 10 | REMEDIES FOR NONCOMPLIANCE
Remedies for Noncompliance
Discussion
 What types of noncompliance issues have you encountered

and how were they resolved?
 Under which circumstances might a federal agency or pass-
through entity apply a remedy of noncompliance instead of a
specific condition?
Action Planning
module.
Financial and Program
Management Standards (2
CFR 200, Subpart D -
Subtitle I)
MODULE 4 | FINANCIAL AND PROGRAM MANAGEMENT STANDARDS (2 CFR 200, SUBPART D -
SUBTITLE I)
FINANCIAL AND PROGRAM

MANAGEMENT STANDARDS (2 CFR
200, SUBPART D - SUBTITLE I)
Module Objective
 Use 2 CFR 200, Subpart D, to locate needed information about financial and program
management standards
During this module you will identify and discuss the financial and programmatic responsibilities in
administering federal grants and use the regulations to analyze a financial management system.
The Uniform Guidance uses language predominately from 2 CFR 215 for financial and program
management requirements. Non-federal entities that previously used A-102 (state and local
governments and Indian tribes) will need to pay particular attention to this subtitle for any required
changes to internal policies due to language differences between the two sets of guidance.
MODULE 4 | FINANCIAL AND PROGRAM MANAGEMENT STANDARDS (2 CFR 200, SUBPART D - SUBTITLE I)
SUBPART D - POST FEDERAL AWARD REQUIREMENTS - STANDARDS FOR FINANCIAL AND PROGRAM MANAGEMENT
Section Source Language New Provisions
200.300 Statutory and National Policy Requirements 2 CFR 215, A-102  States the responsibilities of federal
awarding agencies to ensure non-federal
entities comply with the national policy
requirements
 Requires the terms and conditions of the
federal award identify the national policy
requirements that non-federal entities must
follow
 Requires non-federal entities comply with
FFATA, including the requirements
regarding executive compensation
 Removes sections entitled "Metric System
of Measurement" and "Resource
Conservation and Recovery Act" that were
previously found in 2 CFR 215 and A-102
 Requires non-federal entities to adhere to
whistleblower protections found at 10
U.S.C 2409, 41 U.S.C. 4712, 10 U.S.C.
2324, and 41 U.S.C. 4304 and 4310
 Removes from the administrative
requirements sections entitled "Metric
System of Measurement" and "Resource
Conservation and Recovery Act," however,
these laws must still be included in the
national policy requirements
200.301 Performance Measures 2 CFR 215 Requires performance goals, indicators, and
milestones be identified in the federal award
document.
200.302 Financial Management 2 CFR 215 Requires federal awarding agencies, pass-
through entities, and non-federal entities use
the Assistance Listings (formerly known as
CFDA) number and FAIN on all award
documents.
200.303 Internal Controls Compliance Supplement  Suggests non-federal entities use the
"Standards for Internal Control in the
Federal Government," also known as the
"Green Book," or the “Internal Control
Integrated Framework”, issued by the
Committee of Sponsoring Organizations of
the Treadway Commission (COSO), in
developing and implementing internal
controls
 Requires non-federal entities take prompt
action to rectify noncompliance
 Requires non-federal entities protect
personally identifiable information (PII)
200.304 Bonds 2 CFR 215
200.305 Payment 2 CFR 215  Allows non-federal entities to keep up to

$500 earned on interest from federal
awards for administrative purposes
 Requires all non-federal entities to remit
any interest above the $500 threshold to
the Department of Health and Human
Services Payment Management System
(PMS) on an annual basis
 Revises language regarding payments to
states
 Removes references to specific forms
found in previous guidance
200.306 Cost Sharing or Matching 2 CFR 215 States that for research awards, "voluntary
committed cost sharing is not expected" and
cannot be used as a factor during the merit
review of applications.
200.307 Program Income 2 CFR 215, A-102
200.308 Revisions of Budget and Program Plans 2 CFR 215  No longer requires prior approval to move
funds from direct to indirect costs
 Authorizes federal awarding agencies to
waive prior written approvals, under certain
circumstances
 Requires federal agencies to respond to
budget revisions within 30 days of receipt
of the request or respond within 30 days to
identify when an answer may be
forthcoming
200.309 Period of Performance 2 CFR 215 Clarifies the term "period of performance,"
while still allowing non-federal entities to
request a no cost extension.
SUBTITLE I)
Activity: Financial and Program Management
Directions
Answer the following questions by reviewing §§200.300 to

200.309 in the text, at your table, or at https://www.ecfr.gov.
Identify the correct citation that relates to each question.
1. Do your entity's policies reference the required whistleblower

protections? For federal agencies and pass-through entities:
How will you verify recipient compliance?
2. Does your entity identify the Assistance Listings (formerly
known as CFDA) number and FAIN on all awards?
3. Does your entity use the "Green Book" or COSO's Integrated
Framework as a resource?
4. Does your entity earn more than $500 in interest on federal
awards a year?
5. Does the prohibition of voluntary committed cost sharing
affect your entity?
6. In your experience, do federal agencies typically respond
within 30 days to a budget revision request?
7. Do your internal policies conform with the definition for
"period of performance"?
Lessons
1. Statutory and National Policy Requirements
2. Performance Measurement
3. Financial Management
4. Internal Controls
5. Bonds, Payment, Cost Sharing or Matching, and Program Income
6. Revision of Budget and Program Plans, and Period of Performance
7. Module Capstone: Reviewing a System Against the Administrative Requirements
SUBTITLE I)
SUBTITLE I)
LESSON 1
STATUTORY AND NATIONAL POLICY
REQUIREMENTS
Lesson Objective
4.1.1 Explain how statutory and national policy requirements affect grants management
1.1 §200.300 STATUTORY AND NATIONAL POLICY REQUIREMENTS

§200.300 Statutory and national policy requirements.
(a) The Federal awarding agency must manage and administer

the Federal award in a manner so as to ensure that Federal
funding is expended and associated programs are implemented
in full accordance with U.S. statutory and public policy
requirements: including, but not limited to, those protecting
public welfare, the environment, and prohibiting discrimination.
The Federal awarding agency must communicate to the non-
Federal entity all relevant public policy requirements, including
those in general appropriations provisions, and incorporate
them either directly or by reference in the terms and conditions
of the Federal award.
(b) The non-Federal entity is responsible for complying with all

requirements of the Federal award. For all Federal awards, this
includes the provisions of FFATA, which includes requirements
on executive compensation, and also requirements
implementing the Act for the non-Federal entity at 2 CFR part 25
Financial Assistance Use of Universal Identifier and System for
Award Management and 2 CFR part 170 Reporting Subaward
and Executive Compensation Information. See also statutory
requirements for whistleblower protections at 10 U.S.C. 2409,
41 U.S.C. 4712, and 10 U.S.C. 2324, 41 U.S.C. 4304 and 4310.
The Uniform Guidance requires non-federal entities to administer federal grant awards in
accordance with federal laws and policy requirements. The Uniform Guidance does not provide a
specific list of public policy requirements; however, the Uniform Guidance states the requirements
include, but are not limited to, laws “protecting public welfare, the environment, and prohibiting
discrimination.”
LESSON 1 | STATUTORY AND NATIONAL POLICY REQUIREMENTS
Federal agencies must incorporate public policy requirements into the award agreement. Some
programs have statutory requirements that mandate the incorporation of specific requirements.
Some common public policy requirements include:
 Civil Rights Act of 1964
 Clean Air and Clean Water Act
 Drug-Free Workplace
 Education Amendment of 1972 (Title IX)
 Endangered Species Act of 1973
 Equal Employment Opportunity
 Fly America
Federal Funding Implemented with U.S. Statutory and Public Policy Requirements
Discussion
How does your entity identify applicable statutory and national

policy requirements?
National policy requirements may be categorized according to applicability:

1 To most or all types of grants
2 Primarily to research grants
3 Primarily to construction grants
SUBTITLE I)
The list below identifies the major issues associated with these three categories, a brief summary of
the issue, and examples for each issue. These examples are not comprehensive definitions of
these issues; they are for illustrative purposes only. 1
NATIONAL POLICY REQUIREMENTS AFFECTING MOST OR ALL GRANTS
Issue Summary Example of Impact on Grants
Civil Rights Recipients may not discriminate on Recipients must provide translation
federally funded programs services for beneficiaries with limited
English proficiency
Labor Standards Ensures that the labor practices of All grant-funded contracts which
recipients of federal funds are both exceed the stated dollar thresholds
equitable and safe for employees of the must include clauses specified in 2
recipient organizations CFR 200, Appx II
Hazardous Materials The requirements for the handling and Recipients and their contractors must
disposing of hazardous materials inform employees of hazards to which
protect laborers and mechanics from they may be exposed
unsafe exposure to such materials
Debarment and Protects public and private institutions Recipients should check the
Suspension from fraud, waste, and abuse by exclusions database hosted on the
debarring or suspending those persons System for Award Management (SAM)
that deal in an irresponsible manner before hiring contractors
with the federal government
Drug-Free/Smoke-Free The drug-free requirements promote Grant applicants must certify that they
Workplace the national goal of reducing the use of maintain a drug-free workplace
illicit drugs; the smoke-free workplace
requirements were enacted to protect
children from second-hand smoke in
indoor facilities
Procurement Procedures Procurement activities be performed in All procurement activities planned or

an equitable and competitive manner in carried out by persons or
an effort to promote equal treatment, organizations under a federal grant are
efficiency, and economy in federal grant subject to the general procurement
activities requirements in 2 CFR 200.317 to
200.326
Conflict of Interest in Ensures that federal funds do not Recipients must maintain written
Procurement support unethical contracting practices standards of conduct governing the
performance of employees involved in
contract award and administration
1
Management Concepts offers a two-day course that discusses each compliance issue in depth: Understanding National
Policy Requirements.
Conservation in State and local governments must If a covered recipient procures an

Procurement purchase recycled products per the list EPA-designated item(s), a percentage
maintained by the Environmental of the item(s) must derive from
Protection Agency recovered materials
Utilization of Helps ensure the full participation of Recipients must ensure that
Underserved Businesses underserved businesses concerns (e.g., underserved business concerns are
and Surplus Labor small, disadvantaged and women- involved in contracting to the fullest
owned businesses) in the free extent possible
enterprise system
Domestic Protection Recipients must use domestic carriers For grant-related travel, recipients
for domestic and international air travel must use U.S.-flag carriers for
whenever possible; supply contracts in international air transportation of
excess of the threshold must ensure personnel or property to the extent that
that each end product is considered to service by those carriers is available
have been substantially mined,
produced, or manufactured in the
United States
General Restrictions on Intended to eliminate the use of federal Recipients who receive more than
Lobbying funds to influence specific legislation or $100,000 of federal funds for
administrative rules contracts, grants, and cooperative
agreements, or $150,000 for federal
loan and loan guarantees, must submit
a satisfactory certification and, if
necessary, a disclosure
Restrictions on Political Intended to prevent any perceived or Restricts involvement in partisan

Activity actual use of federal assistance funds elections for state and local
for partisan political purposes government employees working on
grant-funded projects
Crimes and Prohibited Holds federal contractors, recipients, All subgrants and contracts must
Activities and agency employees accountable for include a provision for compliance with
any criminal or prohibited activities they the Copeland “Anti-Kickback” Act
engage in under federal programs
Human Trafficking Prevents assistance funding of Agencies have the right to terminate
organizations that engage in, or whose any award if the recipient (if it is a
employees engage in, human trafficking private entity) or any subrecipients are
found to engage in human trafficking
or forced labor
Counterterrorism Prohibits financial transactions with Government agencies may seize the
terrorist groups property of persons or organizations
that financially support suspected
terrorists, as identified by an official list
of Specially Designated Nationals
SUBTITLE I)
Publications and Federal awarding agency reserves a The grant agreement may require
Copyrights royalty-free, nonexclusive, and recipients to submit to the agency any
irrevocable license to obtain, reproduce, works published and/or copyrighted
publish, or otherwise use, and to under the award
authorize others to use works
copyrighted under a grant for federal
government purposes; agencies may
require acknowledgment of federal
support in publications produced under
grants
Seat Belt Use Designed to protect motor vehicle Each federal agency must encourage
occupants from serious bodily damage its contractors, subcontractors, and
recipients to enforce on-the-job seat
belt policies and programs for their
employees when operating company-
owned, rented or personally-owned
vehicles
NATIONAL POLICY REQUIREMENTS RELATING PRIMARILY TO RESEARCH GRANTS
Protection of Human Safeguards the rights and welfare of Projects must be reviewed and
Subjects human subjects involved in research approved by an Institutional Review
projects supported or conducted (or Board
otherwise regulated) by a federal
agency
Animal Care and Use in Not later than two years after the date A veterinarian must review facilities at
st
Research of enactment of [the 21 Century Cures least once every six months
Act], the Director of National Institutes
of Health, in collaboration with the
Secretary of Agriculture and the
Commissioner of Food and Drugs, shall
complete a review of applicable
regulations and policies for the care and
use of laboratory animals and make
revisions, as appropriate, to reduce
administrative burden on investigators
while maintaining the integrity and
credibility of research findings and
protection of research animals. In
carrying out this effort, the Director of
the National Institutes of Health shall
seek the input of experts, as
appropriate. The Director of the
National Institutes of Health shall:
 identify ways to ensure such
regulations and policies are not
inconsistent, overlapping, or
unnecessarily duplicative, including
with respect to inspection and
review requirements by Federal
agencies and accrediting
associations;
 take steps to eliminate or reduce
identified inconsistencies, overlap,
or duplication among such
regulations and policies; and
 take other actions, as appropriate,
to improve the coordination of
regulations and policies with
respect to research with laboratory
animals.
Research Involving The regulations specify practices for Major actions, e.g., experiments
Recombinant DNA constructing and handling 1) involving new diseases, must be
Molecules recombinant deoxyribonucleic acid approved by the Director of the
(DNA) molecules, and 2) organisms National Institutes of Health
and viruses containing recombinant
DNA molecules to ensure effective
containment of any potentially
hazardous material
Biosafety in Laboratories The CDC and NIH Principles create a If an institution seeks federal
framework for running a research assistance or involvement, its
laboratory that minimizes the risk of adherence to the Principles will
exposure to potentially hazardous normally be factored into any risk
materials for laboratory workers and the assessment performed during the
outside community application and review phases
SUBTITLE I)
Conflict of Interest Regulations prevent recipients of Faculty members should not be

federal funds from using such funds in involved in outside consulting if it
activities engaged in for their exclusive causes a conflict with their teaching,
benefit research, or other professional
responsibilities
Patents Clarifies the legal rights and Recipients must notify the federal
expectations of recipients to any funding agency of any decision not to
inventions or discoveries made with the pursue or maintain a patent at least 30
aid of federal funds, and establish the days before a response is required by
government’s right to use patented the patent office
inventions funded by federal assistance
for government purposes
NATIONAL POLICY REQUIREMENTS APPLYING PRIMARILY TO CONSTRUCTION GRANTS
Environmental Several laws prevent and eliminate Proposed actions that may affect a
Requirements/Impact on unnecessary damage to the floodplain or wetland are subject to
Physical Environment environment and biosphere by requiring review unless they involve “emergency
and Animal Community that major actions with federal work essential to save lives and
involvement incorporate the potential protect property and public health and
environmental costs into the safety....” (EO 11988 §8; EO 11990
decisionmaking process. All reasonable §9) (e.g., emergency rescue effort
alternatives, including a no action after ValuJet Flight 592 crashed into
alternative, must be considered the Florida Everglades)
Historic Preservation The intent of the laws and executive Federal agencies must consider
orders is to preserve historically potential adverse effects on properties
significant districts, sites, buildings, and eligible for listing in the National
structures impacted by projects Register of Historic Places
supported or licensed by the federal
government
Impact on Human Projects under federal grants which Persons displaced due to grant activity
Community involve the acquisition of property must be compensated and relocated
and/or the displacement of people or
businesses are subject to the Uniform
Relocation Assistance and Real
Property Acquisition Policies Act—the
law further applies to all federally
assisted projects administered by state
or local governments which entail
acquiring real property or displacing
people, businesses, or farms
Construction Labor Under the Davis-Bacon Act, all laborers 2 CFR 200, Appx II (D), mandates that
Standards and mechanics employed by recipient construction contracts over
contractors and subcontractors under a $2,000 include a provision requiring
federally involved or supported project contractor compliance with the Davis-
receive certain wage guarantees Bacon Act when required by federal
program legislation
Competition for A succession of executive orders has Varies according to presidential policy
Contracts under encouraged or restricted recipients from
Construction Grants considering labor union agreements in
contracting under grants
Recipients are generally notified of an awarding agency’s requirements for compliance with these
public policy issues through grant award terms and conditions, or through assurances and
certifications submitted with grant applications. However, regardless of whether the recipient is
specifically notified of the applicable laws and regulations, compliance is required.
SUBTITLE I)
LESSON 2
PERFORMANCE MEASUREMENT
Lesson Objective
4.2.1 Explain how the Uniform Guidance expands the use of performance measures in grants
administration
Performance Measurement Life Cycle
LESSON 2 | PERFORMANCE MEASUREMENT
2.1 §200.301 PERFORMANCE MEASUREMENT

§200.301 Performance measurement.
The Federal awarding agency must require the recipient to use

OMB-approved governmentwide standard information
collections when providing financial and performance
information. As appropriate and in accordance with above
mentioned information collections, the Federal awarding agency
must require the recipient to relate financial data to performance
accomplishments of the Federal award. Also, in accordance
with above mentioned governmentwide standard information
collections, and when applicable, recipients must also provide
cost information to demonstrate cost effective practices (e.g.,
through unit cost data). The recipient's performance should be
measured in a way that will help the Federal awarding agency
and other non-Federal entities to improve program outcomes,
share lessons learned, and spread the adoption of promising
practices. The Federal awarding agency should provide
recipients with clear performance goals, indicators, and
milestones as described in §200.210 Information contained in a
Federal award. Performance reporting frequency and content
should be established to not only allow the Federal awarding
agency to understand the recipient progress but also to facilitate
identification of promising practices among recipients and build
the evidence upon which the Federal awarding agency's
program and performance decisions are made.
2 CFR 200 expands the use of performance measures in grants administration. 1 2 CFR 200.301
identifies the responsibilities of both non-federal entities and federal awarding agencies in using
performance measures.
Federal awarding agencies must ensure that:
 Any form or format that recipients are required to submit has OMB approval under the
Paperwork Reduction Act
 Non-federal entities relate financial data to performance accomplishments, where appropriate
 Information related to best practices is disseminated, where appropriate
 Reporting requirements for non-federal entities are identified in the federal award agreement
 Performance data from non-federal entities is applied to future programmatic decisions
Responsibilities for non-federal entities include:
 Relating financial data to performance, when required
 Providing cost information, such as unit cost data, when required
 Complying with the terms and conditions of the award by meeting identified performance goals,
indicators, and milestones (see 2 CFR 200.210(d))
 Complying with reporting requirements and submitting reports in a timely manner
1
Management Concepts offers a course entitled Performance Measurement for Federal Grants Under 2 CFR 200 that
provides an in-depth examination of performance measurement fundamentals and requirements.
SUBTITLE I)
An increasing number of federal grant programs are requiring applicants to prepare a Theory of
Change or logic model to identify a project’s outcomes. An outcome is the measure of the extent in
which a project has achieved its goals and objectives. Under 2 CFR 200, non-federal entities are
held accountable for a project’s ability to meet the identified outcomes in the terms and conditions
of the award.
Discussion
How does your organization comply with the performance

measurement requirements?
LESSON 2 | PERFORMANCE MEASUREMENT
SUBTITLE I)
LESSON 3
FINANCIAL MANAGEMENT
Lesson Objective
 Identify the necessary components of a compliant financial management system
3.1 §200.302 FINANCIAL MANAGEMENT
Financial Management System Requirements
LESSON 3 | FINANCIAL MANAGEMENT
§200.302 Financial management.
(a) Each state must expend and account for the Federal award
in accordance with state laws and procedures for expending
and accounting for the state's own funds. In addition, the state's
and the other non-Federal entity's financial management
systems, including records documenting compliance with
Federal statutes, regulations, and the terms and conditions of
the Federal award, must be sufficient to permit the preparation
of reports required by general and program-specific terms and
conditions; and the tracing of funds to a level of expenditures
adequate to establish that such funds have been used
according to the Federal statutes, regulations, and the terms
and conditions of the Federal award. See also §200.450
Lobbying.
(b) The financial management system of each non-Federal

entity must provide for the following (see also §§200.333
Retention requirements for records, 200.334 Requests for
transfer of records, 200.335 Methods for collection, transmission
and storage of information, 200.336 Access to records, and
200.337 Restrictions on public access to records):
(1) Identification, in its accounts, of all Federal awards received

and expended and the Federal programs under which they were
received. Federal program and Federal award identification
must include, as applicable, the Assistance Listings (formerly
known as CFDA) title and number, Federal award identification
number and year, name of the Federal agency, and name of the
pass-through entity, if any.
(2) Accurate, current, and complete disclosure of the financial

results of each Federal award or program in accordance with
the reporting requirements set forth in §200.327 Financial
reporting and 200.328 Monitoring and reporting program
performance. If a Federal awarding agency requires reporting
on an accrual basis from a recipient that maintains its records
on other than an accrual basis, the recipient must not be
required to establish an accrual accounting system. This
recipient may develop accrual data for its reports on the basis of
an analysis of the documentation on hand. Similarly, a pass-
through entity must not require a subrecipient to establish an
accrual accounting system and must allow the subrecipient to
develop accrual data for its reports on the basis of an analysis
of the documentation on hand.
(3) Records that identify adequately the source and application

of funds for federally-funded activities. These records must
contain information pertaining to Federal awards, authorizations,
obligations, unobligated balances, assets, expenditures, income
and interest and be supported by source documentation.
(4) Effective control over, and accountability for, all funds,
SUBTITLE I)
property, and other assets. The non-Federal entity must

adequately safeguard all assets and assure that they are used
solely for authorized purposes. See §200.303 Internal controls.
(5) Comparison of expenditures with budget amounts for each

Federal award.
(6) Written procedures to implement the requirements of

§200.305 Payment.
(7) Written procedures for determining the allowability of costs in

accordance with Subpart E—Cost Principles of this part and the
terms and conditions of the Federal award.
2 CFR 200.302 requires non-federal entities to develop and maintain adequate financial
management systems. Under the Uniform Guidance, states are required to expend and account for
grant awards in accordance with their own laws and procedures. All other non-federal entities may
implement a financial management system to meet their organizational needs, provided that the
system meets the required standards identified in 2 CFR 200.
A non-federal entity’s financial management system must:
 Identify all federal awards received and expended and include each award’s:
— Assistance Listings number
— FAIN
— Federal awarding agency
— Pass-through entity, if applicable
 Contain accurate, current, and complete disclosure of the financial results of each award
 Contain records that identify and support the source and application of all federal awards,
including authorizations, obligations, balances, expenditures, income, and interest
 Establish and maintain effective control over and accountability for all funds, property, and other
assets
 Allow a comparison of expenditures with budget amounts for each award
 Establish adequate cash management procedures to minimize the time elapsing between the
transfer of funds from the federal government to the non-federal entity and disbursement for
program purposes
 Maintain written procedures for determining the reasonableness, allocability, and allowability of
costs in accordance with the provisions of the applicable cost principles, agency regulations,
and award terms and conditions.
LESSON 3 | FINANCIAL MANAGEMENT
Discussion
Poll: My financial management system is equipped today to

ensure compliance with 2 CFR 200.302 Financial management.
Do you agree or disagree with this statement?
A Agree
B Disagree
Of the requirements listed in §200.302 (b), which do you believe
is most critical and why?
SUBTITLE I)
LESSON 4
INTERNAL CONTROLS
Lesson Objective
4.4.1 List internal controls that use best practices
4.1 §200.303 INTERNAL CONTROLS
Control Components and Summarized Principles
LESSON 4 | INTERNAL CONTROLS
§200.303 Internal controls.
The non-Federal entity must:
(a) Establish and maintain effective internal control over the

Federal award that provides reasonable assurance that the non-
Federal entity is managing the Federal award in compliance
with Federal statutes, regulations, and the terms and conditions
of the Federal award. These internal controls should be in
compliance with guidance in “Standards for Internal Control in
the Federal Government” issued by the Comptroller General of
the United States or the “Internal Control Integrated
Framework”, issued by the Committee of Sponsoring
Organizations of the Treadway Commission (COSO).
(b) Comply with Federal statutes, regulations, and the terms and
conditions of the Federal awards.
(c) Evaluate and monitor the non-Federal entity's compliance

with statutes, regulations and the terms and conditions of
Federal awards.
(d) Take prompt action when instances of noncompliance are

identified including noncompliance identified in audit findings.
(e) Take reasonable measures to safeguard protected

personally identifiable information and other information the
Federal awarding agency or pass-through entity designates as
sensitive or the non-Federal entity considers sensitive
consistent with applicable Federal, state, local, and tribal laws
regarding privacy and obligations of confidentiality.
2 CFR 200.303 requires non-federal entities to establish and maintain adequate internal controls to
ensure the administration of a federal award is in full compliance with all regulations, requirements,
terms and conditions, and laws. The Uniform Guidance suggests a non-federal entity's internal
control systems align with the "Standards for Internal Control in the Federal Government,"
commonly referred to as "The Green Book," or with the "Internal Control - Integrated Framework"
issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Adherence to the Green Book or the Integrated Framework is not a requirement, but merely a
suggested best practice. The annual single audit Compliance Supplement provides additional
guidance for auditors and non-federal entities in implementing and evaluating adequate internal
controls. Part 6 of the Compliance Supplement uses the Green Book to provide suggestions on key
internal control considerations.
SUBTITLE I)
Refer to Website
 The 2017 Compliance Supplement can be found at:

https://www.whitehouse.gov/sites/whitehouse.gov/files/omb/circulars/A13
3/2017/Compliance_Supplement_2017.pdf
 The 2018 Compliance Supplement can be found at:
https://www.whitehouse.gov/wp-content/uploads/2018/05/2018-
Compliance-Supplement.pdf
 The Green Book may be downloaded for free at:
https://www.gao.gov/products/GAO-14-704G
 Resources for the "Internal Control - Integrated Framework" are available from
COSO at:
http://www.coso.org/IC.htm
Non-federal entities will probably find the Integrated Framework more useful than the Green Book.
COSO updated the Integrated Framework in 2013 and recipients and auditors should verify they
are working from the most recent version of the framework. The framework is only available for
purchase; however, COSO does provide some free resources on the website.
A non-federal entity's internal control procedures must also ensure:
 prompt action is taken to rectify noncompliance
 personally identifiable information (PII), and other information an awarding agency deems as
sensitive information, is protected
Non-federal entities should review their management systems to verify adequate internal controls.
Key management systems include:
 Accounting
 Procurement
 Personnel
 Property management
 Travel
 Information technology
Discussion
Poll: Are you familiar with the COSO Internal Control –

Integrated Framework?
A Yes
B No
Poll: Does your entity use the COSO Internal Control –
Integrated Framework when evaluating your internal controls?
A Yes
B No
LESSON 4 | INTERNAL CONTROLS
SUBTITLE I)
LESSON 5
BONDS, PAYMENT, COST SHARING OR
MATCHING, AND PROGRAM INCOME
Lesson Objective
4.5.1 Explain payment procedures for federal awards, and comply with bonding, cost sharing,
matching, and program income requirements.
5.1 §200.304 BONDS

§200.304 Bonds.
The Federal awarding agency may include a provision on

bonding, insurance, or both in the following circumstances:
(a) Where the Federal government guarantees or insures the

repayment of money borrowed by the recipient, the Federal
awarding agency, at its discretion, may require adequate
bonding and insurance if the bonding and insurance
requirements of the non-Federal entity are not deemed
adequate to protect the interest of the Federal government.
(b) The Federal awarding agency may require adequate fidelity

bond coverage where the non-Federal entity lacks sufficient
coverage to protect the Federal government's interest.
(c) Where bonds are required in the situations described above,

the bonds must be obtained from companies holding certificates
of authority as acceptable sureties, as prescribed in 31 CFR
Part 223, “Surety Companies Doing Business with the United
States.”
LESSON 5 | BONDS, PAYMENT, COST SHARING OR MATCHING, AND PROGRAM INCOME
5.2 §200.305 PAYMENT
Payment Methods
§200.305 Payment.
(a) For states, payments are governed by Treasury-State CMIA

agreements and default procedures codified at 31 CFR Part 205
“Rules and Procedures for Efficient Federal-State Funds
Transfers” and TFM 4A-2000 Overall Disbursing Rules for All
Federal Agencies.
(b) For non-Federal entities other than states, payments

methods must minimize the time elapsing between the transfer
of funds from the United States Treasury or the pass-through
entity and the disbursement by the non-Federal entity whether
the payment is made by electronic funds transfer, or issuance or
redemption of checks, warrants, or payment by other means.
See also §200.302 Financial management paragraph (b)(6).
Except as noted elsewhere in this part, Federal agencies must
require recipients to use only OMB-approved standard
government wide information collection requests to request
payment.
SUBTITLE I)
(1) The non-Federal entity must be paid in advance, provided it

maintains or demonstrates the willingness to maintain both
written procedures that minimize the time elapsing between the
transfer of funds and disbursement by the non-Federal entity,
and financial management systems that meet the standards for
fund control and accountability as established in this part.
Advance payments to a non-Federal entity must be limited to
the minimum amounts needed and be timed to be in
accordance with the actual, immediate cash requirements of the
non-Federal entity in carrying out the purpose of the approved
program or project. The timing and amount of advance
payments must be as close as is administratively feasible to the
actual disbursements by the non-Federal entity for direct
program or project costs and the proportionate share of any
allowable indirect costs. The non-Federal entity must make
timely payment to contractors in accordance with the contract
provisions.
(2) Whenever possible, advance payments must be

consolidated to cover anticipated cash needs for all Federal
awards made by the Federal awarding agency to the recipient.
(i) Advance payment mechanisms include, but are not limited to,
Treasury check and electronic funds transfer and must comply
with applicable guidance in 31 CFR part 208.
(ii) Non-Federal entities must be authorized to submit requests

for advance payments and reimbursements at least monthly
when electronic fund transfers are not used, and as often as
they like when electronic transfers are used, in accordance with
the provisions of the Electronic Fund Transfer Act (15 U.S.C.
1693-1693r).
(3) Reimbursement is the preferred method when the

requirements in paragraph (b) cannot be met, when the Federal
awarding agency sets a specific condition per §200.207 Specific
conditions, or when the non-Federal entity requests payment by
reimbursement. This method may be used on any Federal
award for construction, or if the major portion of the construction
project is accomplished through private market financing or
Federal loans, and the Federal award constitutes a minor
portion of the project. When the reimbursement method is used,
the Federal awarding agency or pass-through entity must make
payment within 30 calendar days after receipt of the billing,
unless the Federal awarding agency or pass-through entity
reasonably believes the request to be improper.
(4) If the non-Federal entity cannot meet the criteria for advance
payments and the Federal awarding agency or pass-through
entity has determined that reimbursement is not feasible
because the non-Federal entity lacks sufficient working capital,
the Federal awarding agency or pass-through entity may
provide cash on a working capital advance basis. Under this

procedure, the Federal awarding agency or pass-through entity
must advance cash payments to the non-Federal entity to cover
its estimated disbursement needs for an initial period generally
geared to the non-Federal entity's disbursing cycle. Thereafter,
the Federal awarding agency or pass-through entity must
reimburse the non-Federal entity for its actual cash
disbursements. Use of the working capital advance method of
payment requires that the pass-through entity provide timely
advance payments to any subrecipients in order to meet the
subrecipient's actual cash disbursements. The working capital
advance method of payment must not be used by the pass-
through entity if the reason for using this method is the
unwillingness or inability of the pass-through entity to provide
timely advance payments to the subrecipient to meet the
subrecipient's actual cash disbursements.
(5) Use of resources before requesting cash advance payments.

To the extent available, the non-Federal entity must disburse
funds available from program income (including repayments to a
revolving fund), rebates, refunds, contract settlements, audit
recoveries, and interest earned on such funds before requesting
additional cash payments.
(6) Unless otherwise required by Federal statutes, payments for

allowable costs by non-Federal entities must not be withheld at
any time during the period of performance unless the conditions
of §§200.207 Specific conditions, Subpart D—Post Federal
Award Requirements of this part, 200.338 Remedies for
Noncompliance, or one or more of the following applies:
(i) The non-Federal entity has failed to comply with the project
objectives, Federal statutes, regulations, or the terms and
conditions of the Federal award.
(ii) The non-Federal entity is delinquent in a debt to the United

States as defined in OMB Guidance A-129, “Policies for Federal
Credit Programs and Non-Tax Receivables.” Under such
conditions, the Federal awarding agency or pass-through entity
may, upon reasonable notice, inform the non-Federal entity that
payments must not be made for obligations incurred after a
specified date until the conditions are corrected or the
indebtedness to the Federal Government is liquidated.
(iii) A payment withheld for failure to comply with Federal award

conditions, but without suspension of the Federal award, must
be released to the non-Federal entity upon subsequent
compliance. When a Federal award is suspended, payment
adjustments will be made in accordance with §200.342 Effects
of suspension and termination.
(iv) A payment must not be made to a non-Federal entity for

amounts that are withheld by the non-Federal entity from
SUBTITLE I)
payment to contractors to assure satisfactory completion of

work. A payment must be made when the non-Federal entity
actually disburses the withheld funds to the contractors or to
escrow accounts established to assure satisfactory completion
of work.
(7) Standards governing the use of banks and other institutions

as depositories of advance payments under Federal awards are
as follows.
(i) The Federal awarding agency and pass-through entity must

not require separate depository accounts for funds provided to a
non-Federal entity or establish any eligibility requirements for
depositories for funds provided to the non-Federal entity.
However, the non-Federal entity must be able to account for the
receipt, obligation and expenditure of funds.
(ii) Advance payments of Federal funds must be deposited and

maintained in insured accounts whenever possible.
(8) The non-Federal entity must maintain advance payments of

Federal awards in interest-bearing accounts, unless the
following apply.
(i) The non-Federal entity receives less than $120,000 in

Federal awards per year.
(ii) The best reasonably available interest-bearing account

would not be expected to earn interest in excess of $500 per
year on Federal cash balances.
(iii) The depository would require an average or minimum

balance so high that it would not be feasible within the expected
Federal and non-Federal cash resources.
(iv) A foreign government or banking system prohibits or

precludes interest bearing accounts.
(9) Interest earned amounts up to $500 per year may be

retained by the non-Federal entity for administrative expense.
Any additional interest earned on Federal advance payments
deposited in interest-bearing accounts must be remitted
annually to the Department of Health and Human Services
Payment Management System (PMS) through an electronic
medium using either Automated Clearing House (ACH) network
or a Fedwire Funds Service payment. Remittances must include
pertinent information of the payee and nature of payment in the
memo area (often referred to as “addenda records” by Financial
Institutions) as that will assist in the timely posting of interest
earned on federal funds. Pertinent details include the Payee
Account Number (PAN) if the payment originated from PMS, or
Agency information if the payment originated from ASAP, NSF
or another federal agency payment system. The remittance

must be submitted as follows:
(i) For ACH Returns:
Routing Number: 051036706
Account number: 303000
Bank Name and Location: Credit Gateway—ACH Receiver St.

Paul, MN
(ii) For Fedwire Returns*:
Routing Number: 021030004
Account number: 75010501
Bank Name and Location: Federal Reserve Bank Treas

NYC/Funds Transfer Division New York, NY
(* Please note organization initiating payment is likely to incur a

charge from your Financial Institution for this type of payment)
(iii) For International ACH Returns:
Beneficiary Account: Federal Reserve Bank of New York/ITS

(FRBNY/ITS)
Bank: Citibank N.A. (New York)
Swift Code: CITIUS33
Account Number: 36838868
Bank Address: 388 Greenwich Street, New York, NY 10013

USA
Payment Details (Line 70): Agency
Name (abbreviated when possible) and ALC Agency POC:

Michelle Haney, (301) 492-5065
(iv) For recipients that do not have electronic remittance

capability, please make check** payable to: “The Department of
Health and Human Services.”
Mail Check to Treasury approved lockbox:
HHS Program Support Center, P.O. Box 530231, Atlanta, GA

30353-0231
(** Please allow 4-6 weeks for processing of a payment by
SUBTITLE I)
check to be applied to the appropriate PMS account)
(v) Any additional information/instructions may be found on the

PMS Web site at http://www.dpm.psc.gov/.
2 CFR 200.305 establishes the disbursement procedures of federal funding to non-federal entities.
The following are important provisions contained in this section.
 Payment Disbursements. Payments should be made in advance, unless the non-federal entity
cannot comply with established requirements as explained at 2 CFR 200.305(b)(1). When a
non-federal entity cannot adequately comply with requirements, payment should be made on a
reimbursement method. Advance payments should be made as close as possible to the actual
disbursement of the funds. Non-federal entities should use all available resources, such as
program income, before requesting additional disbursements.
 Interest Earned. A non-federal entity may retain up to $500 earned on interest from federal
awards for administrative purposes. Any amount in excess of the $500 threshold should be
remitted to the Department of Health and Human Services' Payment Management System
(PMS).
Discussion
 What policies does your entity have regarding grant

payments?
 How could those policies be improved?
5.3 §200.306 COST SHARING OR MATCHING

§200.306 Cost sharing or matching.
(a) Under Federal research proposals, voluntary committed cost

sharing is not expected. It cannot be used as a factor during the
merit review of applications or proposals, but may be
considered if it is both in accordance with Federal awarding
agency regulations and specified in a notice of funding
opportunity. Criteria for considering voluntary committed cost
sharing and any other program policy factors that may be used
to determine who may receive a Federal award must be
explicitly described in the notice of funding opportunity. See also
§§200.414 Indirect (F&A) costs, 200.203 Notices of funding
opportunities, and Appendix I to Part 200—Full Text of Notice of
Funding Opportunity.
(b) For all Federal awards, any shared costs or matching funds
and all contributions, including cash and third party in-kind
contributions, must be accepted as part of the non-Federal
entity's cost sharing or matching when such contributions meet
all of the following criteria:
(1) Are verifiable from the non-Federal entity's records;
(2) Are not included as contributions for any other Federal

award;
(3) Are necessary and reasonable for accomplishment of project

or program objectives;
(4) Are allowable under Subpart E—Cost Principles of this part;
(5) Are not paid by the Federal Government under another

Federal award, except where the Federal statute authorizing a
program specifically provides that Federal funds made available
for such program can be applied to matching or cost sharing
requirements of other Federal programs;
(6) Are provided for in the approved budget when required by

the Federal awarding agency; and
(7) Conform to other provisions of this part, as applicable.
(c) Unrecovered indirect costs, including indirect costs on cost

sharing or matching may be included as part of cost sharing or
matching only with the prior approval of the Federal awarding
agency. Unrecovered indirect cost means the difference
between the amount charged to the Federal award and the
amount which could have been charged to the Federal award
under the non-Federal entity's approved negotiated indirect cost
rate.
(d) Values for non-Federal entity contributions of services and
SUBTITLE I)
property must be established in accordance with the cost

principles in Subpart E—Cost Principles. If a Federal awarding
agency authorizes the non-Federal entity to donate buildings or
land for construction/facilities acquisition projects or long-term
use, the value of the donated property for cost sharing or
matching must be the lesser of paragraphs (d)(1) or (2) of this
section.
(1) The value of the remaining life of the property recorded in

the non-Federal entity's accounting records at the time of
donation.
(2) The current fair market value. However, when there is

sufficient justification, the Federal awarding agency may
approve the use of the current fair market value of the donated
property, even if it exceeds the value described in (1) above at
the time of donation.
(e) Volunteer services furnished by third-party professional and

technical personnel, consultants, and other skilled and unskilled
labor may be counted as cost sharing or matching if the service
is an integral and necessary part of an approved project or
program. Rates for third-party volunteer services must be
consistent with those paid for similar work by the non-Federal
entity. In those instances in which the required skills are not
found in the non-Federal entity, rates must be consistent with
those paid for similar work in the labor market in which the non-
Federal entity competes for the kind of services involved. In
either case, paid fringe benefits that are reasonable, necessary,
allocable, and otherwise allowable may be included in the
valuation.
(f) When a third-party organization furnishes the services of an

employee, these services must be valued at the employee's
regular rate of pay plus an amount of fringe benefits that is
reasonable, necessary, allocable, and otherwise allowable, and
indirect costs at either the third-party organization's approved
federally negotiated indirect cost rate or, a rate in accordance
with §200.414 Indirect (F&A) costs, paragraph (d), provided
these services employ the same skill(s) for which the employee
is normally paid. Where donated services are treated as indirect
costs, indirect cost rates will separate the value of the donated
services so that reimbursement for the donated services will not
be made.
(g) Donated property from third parties may include such items
as equipment, office supplies, laboratory supplies, or workshop
and classroom supplies. Value assessed to donated property
included in the cost sharing or matching share must not exceed
the fair market value of the property at the time of the donation.
(h) The method used for determining cost sharing or matching
for third-party-donated equipment, buildings and land for which

title passes to the non-Federal entity may differ according to the
purpose of the Federal award, if paragraph (h)(1) or (2) of this
section applies.
(1) If the purpose of the Federal award is to assist the non-

Federal entity in the acquisition of equipment, buildings or land,
the aggregate value of the donated property may be claimed as
cost sharing or matching.
(2) If the purpose of the Federal award is to support activities

that require the use of equipment, buildings or land, normally
only depreciation charges for equipment and buildings may be
made. However, the fair market value of equipment or other
capital assets and fair rental charges for land may be allowed,
provided that the Federal awarding agency has approved the
charges. See also §200.420 Considerations for selected items
of cost.
(i) The value of donated property must be determined in

accordance with the usual accounting policies of the non-
Federal entity, with the following qualifications:
(1) The value of donated land and buildings must not exceed its
fair market value at the time of donation to the non-Federal
entity as established by an independent appraiser (e.g., certified
real property appraiser or General Services Administration
representative) and certified by a responsible official of the non-
Federal entity as required by the Uniform Relocation Assistance
and Real Property Acquisition Policies Act of 1970, as
amended, (42 U.S.C. 4601-4655) (Uniform Act) except as
provided in the implementing regulations at 49 CFR part 24.
(2) The value of donated equipment must not exceed the fair
market value of equipment of the same age and condition at the
time of donation.
(3) The value of donated space must not exceed the fair rental
value of comparable space as established by an independent
appraisal of comparable space and facilities in a privately-
owned building in the same locality.
(4) The value of loaned equipment must not exceed its fair
rental value.
(j) For third-party in-kind contributions, the fair market value of

goods and services must be documented and to the extent
feasible supported by the same methods used internally by the
non-Federal entity.
(k) For IHEs, see also OMB memorandum M-01-06, dated

January 5, 2001, Clarification of OMB A-21 Treatment of
Voluntary Uncommitted Cost Sharing and Tuition Remission
SUBTITLE I)
Costs.
Cost sharing or matching funds are funds that go toward a federal grant project but do not come
from the federal government. 2 CFR 200.306 identifies the rules for cost sharing and matching in
detail.
Some federal grant programs require that a portion of the project be funded by the recipient or third
party. For programs that do not require a cost share or match, applicants may offer to contribute
funds. This is called “voluntary committed cost sharing,” and the Uniform Guidance prohibits federal
awarding agencies from considering such funding in the merit review process or calculating the
indirect cost rate.
Under 2 CFR 200.306(b), non-federal entities must meet all the following standards for items to be
considered as part of cost sharing or matching requirements:
 Are verifiable from the non-federal entity’s records
 Not included as contributions for another award
 Be necessary and reasonable to meet the project’s objectives
 Allowable under the cost principles
 Not paid by the federal government under another award
 Provided for in the approved budget, when required
 In compliance with other provisions of 2 CFR 200
Source of Cost Share or Examples of Contributions Valuation Requirements
Matching Contributions
Recipient Unrecovered indirect costs Difference between the amount

charged to the federal award and
the amount which could have been
charged to the award; must have
prior approval
Services and property Must be in accordance with the

cost principles; value is
established by the lesser of the
remaining life of the property or the
current fair market value
3rd Party Volunteer services Must be valued at the employee's

regular pay plus fringe benefits
that meet 2 CFR 200 standards
Donated property Fair market value at the time of

donation and in accordance with
the NFE's account policies
In-kind contributions Fair market value
5.4 §200.307 PROGRAM INCOME
Program Income Comparison
§200.307 Program income.
(a) General. Non-Federal entities are encouraged to earn

income to defray program costs where appropriate.
(b) Cost of generating program income. If authorized by Federal

regulations or the Federal award, costs incidental to the
generation of program income may be deducted from gross
income to determine program income, provided these costs
have not been charged to the Federal award.
(c) Governmental revenues. Taxes, special assessments,

levies, fines, and other such revenues raised by a non-Federal
entity are not program income unless the revenues are
specifically identified in the Federal award or Federal awarding
agency regulations as program income.
SUBTITLE I)
(d) Property. Proceeds from the sale of real property,

equipment, or supplies are not program income; such proceeds
will be handled in accordance with the requirements of Subpart
D—Post Federal Award Requirements of this part, Property
Standards §§200.311 Real property, 200.313 Equipment, and
200.314 Supplies, or as specifically identified in Federal
statutes, regulations, or the terms and conditions of the Federal
award.
(e) Use of program income. If the Federal awarding agency

does not specify in its regulations or the terms and conditions of
the Federal award, or give prior approval for how program
income is to be used, paragraph (e)(1) of this section must
apply. For Federal awards made to IHEs and nonprofit research
institutions, if the Federal awarding agency does not specify in
its regulations or the terms and conditions of the Federal award
how program income is to be used, paragraph (e)(2) of this
section must apply. In specifying alternatives to paragraphs
(e)(1) and (2) of this section, the Federal awarding agency may
distinguish between income earned by the recipient and income
earned by subrecipients and between the sources, kinds, or
amounts of income. When the Federal awarding agency
authorizes the approaches in paragraphs (e)(2) and (3) of this
section, program income in excess of any amounts specified
must also be deducted from expenditures.
(1) Deduction. Ordinarily program income must be deducted

from total allowable costs to determine the net allowable costs.
Program income must be used for current costs unless the
Federal awarding agency authorizes otherwise. Program
income that the non-Federal entity did not anticipate at the time
of the Federal award must be used to reduce the Federal award
and non-Federal entity contributions rather than to increase the
funds committed to the project.
(2) Addition. With prior approval of the Federal awarding agency

(except for IHEs and nonprofit research institutions, as
described in paragraph (e) of this section) program income may
be added to the Federal award by the Federal agency and the
non-Federal entity. The program income must be used for the
purposes and under the conditions of the Federal award.
(3) Cost sharing or matching. With prior approval of the Federal

awarding agency, program income may be used to meet the
cost sharing or matching requirement of the Federal award. The
amount of the Federal award remains the same.
(f) Income after the period of performance. There are no Federal

requirements governing the disposition of income earned after
the end of the period of performance for the Federal award,
unless the Federal awarding agency regulations or the terms
and conditions of the Federal award provide otherwise. The
Federal awarding agency may negotiate agreements with

recipients regarding appropriate uses of income earned after the
period of performance as part of the grant closeout process.
See also §200.343 Closeout.
(g) Unless the Federal statute, regulations, or terms and

conditions for the Federal award provide otherwise, the non-
Federal entity has no obligation to the Federal awarding agency
with respect to program income earned from license fees and
royalties for copyrighted material, patents, patent applications,
trademarks, and inventions made under a Federal award to
which 37 CFR part 401,“Rights to Inventions Made by Nonprofit
Organizations and Small Business Firms Under Government
Awards, Contracts and Cooperative Agreements” is applicable.
Discussion
 What policies does your entity have regarding program

income?
 What internal controls do you have to support these policies?
SUBTITLE I)
LESSON 6
REVISION OF BUDGET AND PROGRAM
PLANS, AND PERIOD OF
PERFORMANCE
Lesson Objective
4.6.1 Identify situations that require agency prior approval
6.1 §200.308 REVISION OF BUDGET AND PROGRAM PLANS

The Uniform Guidance addresses prior approval requirements in 2 CFR 200.308 and in the cost
principles.
For non-construction awards, 2 CFR 200.308 requires prior agency approval for the following items:
 Change in scope or objective
 Change in key personnel
 Disengagement of key personnel
 Inclusion of cost that require approval under the cost principles
 Transfer of funds budgeted for participant support costs
 Subawarding or contracting of substantive work
 Changes in cost share or matching
 Additional federal funds
Federal awarding agencies have the ability to waive the prior approval requirement for most items,
except for changes in scope or objective. For research awards, certain prior approval requirements
are automatically waived unless the federal awarding agency states otherwise. These privileges are
called “Expanded authorities,” and they can apply to non research awards if the parties so agree.
The expanded authorities allow a recipient to:
 Incur project costs up to 90 days before the beginning of the federal award. Costs must be
allowable and are incurred at the recipient’s risk.
 Initiate a one-time extension of the period of performance for up to twelve months
 Carry forward unobligated balances to subsequent periods of performance
Under 2 CFR 200.308(e), the federal awarding agency may require prior approval for the transfer of
funds among direct cost categories when the federal share of the project exceeds the Simplified
Acquisition Threshold and the total amount of such transfers exceeds 10% of the total approved
budget.
The restrictions for construction awards are listed at 2 CFR 200.308(g).
LESSON 6 | REVISION OF BUDGET AND PROGRAM PLANS, AND PERIOD OF PERFORMANCE
To request prior approval for a revision, recipients must generally use the same format they used in
their grant application, unless specified otherwise. The awarding agency must respond to the
request within 30 calendar days.
§200.308 Revision of budget and program plans.
(a) The approved budget for the Federal award summarizes the
financial aspects of the project or program as approved during
the Federal award process. It may include either the Federal
and non-Federal share (see §200.43 Federal share) or only the
Federal share, depending upon Federal awarding agency
requirements. It must be related to performance for program
evaluation purposes whenever appropriate.
(b) Recipients are required to report deviations from budget or

project scope or objective, and request prior approvals from
Federal awarding agencies for budget and program plan
revisions, in accordance with this section.
(c)(1) For non-construction Federal awards, recipients must

request prior approvals from Federal awarding agencies for one
or more of the following program or budget-related reasons:
(i) Change in the scope or the objective of the project or

program (even if there is no associated budget revision
requiring prior written approval).
(ii) Change in a key person specified in the application or the

Federal award.
(iii) The disengagement from the project for more than three
months, or a 25 percent reduction in time devoted to the project,
by the approved project director or principal investigator.
(iv) The inclusion, unless waived by the Federal awarding

agency, of costs that require prior approval in accordance with
Subpart E—Cost Principles of this part or 45 CFR part 75
Appendix IX, “Principles for Determining Costs Applicable to
Research and Development under Awards and Contracts with
Hospitals,” or 48 CFR part 31, “Contract Cost Principles and
Procedures,” as applicable.
(v) The transfer of funds budgeted for participant support costs

as defined in §200.75 Participant support costs to other
categories of expense.
SUBTITLE I)
(vi) Unless described in the application and funded in the

approved Federal awards, the subawarding, transferring or
contracting out of any work under a Federal award, including
fixed amount subawards as described in §200.332 Fixed
amount subawards. This provision does not apply to the
acquisition of supplies, material, equipment or general support
services.
(vii) Changes in the approved cost-sharing or matching provided

by the non-Federal entity.
(viii) The need arises for additional Federal funds to complete

the project.
(2) No other prior approval requirements for specific items may

be imposed unless an exception has been approved by OMB.
See also §§200.102 Exceptions and 200.407 Prior written
approval (prior approval).
(d) Except for requirements listed in paragraph (c)(1) of this

section, the Federal awarding agency is authorized, at its
option, to waive prior written approvals required by paragraph
(c) this section. Such waivers may include authorizing recipients
to do any one or more of the following:
(1) Incur project costs 90 calendar days before the Federal

awarding agency makes the Federal award. Expenses more
than 90 calendar days pre-award require prior approval of the
Federal awarding agency. All costs incurred before the Federal
awarding agency makes the Federal award are at the recipient's
risk (i.e., the Federal awarding agency is under no obligation to
reimburse such costs if for any reason the recipient does not
receive a Federal award or if the Federal award is less than
anticipated and inadequate to cover such costs). See also
§200.458 Pre-award costs.
(2) Initiate a one-time extension of the period of performance by

up to 12 months unless one or more of the conditions outlined in
paragraphs (d)(2)(i) through (iii) of this section apply. For one-
time extensions, the recipient must notify the Federal awarding
agency in writing with the supporting reasons and revised period
of performance at least 10 calendar days before the end of the
period of performance specified in the Federal award. This one-
time extension may not be exercised merely for the purpose of
using unobligated balances. Extensions require explicit prior
Federal awarding agency approval when:
(i) The terms and conditions of the Federal award prohibit the
extension.
(ii) The extension requires additional Federal funds.
(iii) The extension involves any change in the approved

objectives or scope of the project.
(3) Carry forward unobligated balances to subsequent periods

of performance.
(4) For Federal awards that support research, unless the

Federal awarding agency provides otherwise in the Federal
award or in the Federal awarding agency's regulations, the prior
approval requirements described in paragraph (d) are
automatically waived (i.e., recipients need not obtain such prior
approvals) unless one of the conditions included in paragraph
(d)(2) applies.
(e) The Federal awarding agency may, at its option, restrict the
transfer of funds among direct cost categories or programs,
functions and activities for Federal awards in which the Federal
share of the project exceeds the Simplified Acquisition
Threshold and the cumulative amount of such transfers exceeds
or is expected to exceed 10 percent of the total budget as last
approved by the Federal awarding agency. The Federal
awarding agency cannot permit a transfer that would cause any
Federal appropriation to be used for purposes other than those
consistent with the appropriation.
(f) All other changes to non-construction budgets, except for the

changes described in paragraph (c) of this section, do not
require prior approval (see also §200.407 Prior written approval
(prior approval)).
(g) For construction Federal awards, the recipient must request

prior written approval promptly from the Federal awarding
agency for budget revisions whenever paragraph (g)(1), (2), or
(3) of this section applies.
(1) The revision results from changes in the scope or the

objective of the project or program.
(2) The need arises for additional Federal funds to complete the
project.
(3) A revision is desired which involves specific costs for which

prior written approval requirements may be imposed consistent
with applicable OMB cost principles listed in Subpart E—Cost
Principles of this part.
(4) No other prior approval requirements for budget revisions

may be imposed unless an exception has been approved by
OMB.
(5) When a Federal awarding agency makes a Federal award

that provides support for construction and non-construction
work, the Federal awarding agency may require the recipient to
SUBTITLE I)
obtain prior approval from the Federal awarding agency before

making any fund or budget transfers between the two types of
work supported.
(h) When requesting approval for budget revisions, the recipient

must use the same format for budget information that was used
in the application, unless the Federal awarding agency indicates
a letter of request suffices.
(i) Within 30 calendar days from the date of receipt of the

request for budget revisions, the Federal awarding agency must
review the request and notify the recipient whether the budget
revisions have been approved. If the revision is still under
consideration at the end of 30 calendar days, the Federal
awarding agency must inform the recipient in writing of the date
when the recipient may expect the decision.
2 CFR 200.407, located in Subpart E - Cost Principles, provides a comprehensive list of all
situations that require prior written approval. The sections in the administrative requirements that
require prior approval are:
 2 CFR 200.201 Use of grant agreements (including fixed amount awards), cooperative
agreements, and contracts, paragraph (b)(5)
 2 CFR 200.306 Cost sharing or matching
 2 CFR 200.307 Program income
 2 CFR 200.308 Revision of budget and program plans
 2 CFR 200.332 Fixed amount subawards
Discussion
 Discuss your experiences in obtaining or granting prior

approval
 Poll: Has your entity ever granted, or requested, a no-cost
extension?
A Yes
B No
 Poll: Have you experienced a situation in which a recipient
has tried to initiate a one-time extension to the period of
performance merely for the purpose of using unobligated
balances (which goes against 2 CFR 200.308)?
A Yes
B No
6.2 §200.309 PERIOD OF PERFORMANCE

§200.309 Period of performance.
A non-Federal entity may charge to the Federal award only

allowable costs incurred during the period of performance
(except as described in §200.461 Publication and printing costs)
and any costs incurred before the Federal awarding agency or
pass-through entity made the Federal award that were
authorized by the Federal awarding agency or pass-through
entity.
Under the Uniform Guidance, the only allowable costs to an award are those
incurred during the period of performance or authorized pre-award costs. The
period of performance is designated as the start and end dates of the project
as identified in the federal award (see 2 CFR 200.77). Non-federal entities may
request a no cost extension to the award, as provided for by 2 CFR 200.308.
SUBTITLE I)
LESSON 7
MODULE CAPSTONE: REVIEWING A
SYSTEM AGAINST THE
Capstone Objective
This capstone will allow you to do the following:
4.7.1 Practice using 2 CFR 200, Subpart D, to locate needed information about financial and
program management standards
LESSON 7 | MODULE CAPSTONE: REVIEWING A SYSTEM AGAINST THE ADMINISTRATIVE
REQUIREMENTS
7.1 MODULE CAPSTONE: REVIEWING A SYSTEM AGAINST THE

Overview
Work as a team to evaluate an entity's compliance with the provisions in the Uniform Guidance.
Scenario
Assume that you work for Helping Hands, a mid-sized nonprofit organization that receives federal
funds. Helping Hands has just hired a new executive director. She has appointed task forces to
review all Helping Hands policies and procedures for compliance with federal requirements. You
and your table group are the task force responsible for reviewing the Accounting Policy for
compliance with the Uniform Guidance.
Directions
1. In your teams, divide up Subpart D - Post Federal Award Requirements Subtitle I: Standards for
Financial and Program Management (2 CFR 200.300 to 2 CFR 200.309)
2. Review the section(s) assigned to you and develop a list of requirements for that section
3. Read the Helping Hands Accounting Policies. For each requirement on your list, determine
whether:
— Helping Hands' policy adequately addresses the requirements. Remember that Helping
Hands may be more restrictive than the Uniform Guidance, but may not be less restrictive.
For example, non-federal entities are required to complete a biennial equipment inventory.
If Helping Hand's Equipment Policy requires an inventory every six months, this would be
in compliance; however, if Helping Hands has a policy of conducting an equipment
inventory every three years, then the entity would not be in compliance.
— Helping Hands' policy addresses the requirement but needs improvement; or
— Helping Hands' policy does not address the requirement.
4. Next, determine whether any provisions of the Uniform Guidance that should be reflected in the
Accounting Policy are missing. Be prepared to explain to the executive director what should be
added and why.
5. Provide citations for all answers.
ACCOUNTING POLICIES AND PROCEDURES - Excerpts

1. All funds will be kept on deposit with Friendly Neighbors Bank. Changes in financial institution
must be approved by the Board of Directors; the financial institution must be FDIC-insured.
2. All checks less than $1,000 must be signed by the Executive Director or the Financial Officer;
checks of $1,000 or more must be signed by both the Executive Director and the Financial
Officer.
SUBTITLE I)
3. All incoming funds must be identified as "restricted" or "nonrestricted." Restricted funds must be
tracked properly from receipt through expenditure to allow reporting back to donors and
sponsors. Incoming funds should be deposited no less frequently than weekly to ensure control
over assets and to maximize interest earnings. Fees paid by program participants shall be
considered restricted to the activity funding source unless the agreement with the funding
source specifies otherwise. Where multiple funding sources support an activity, incoming fees
will be allocated on the basis of percentage of support. The Financial Officer will review all
allocations monthly to ensure proper percentages have been applied.
4. Accounting is on an accrual basis. Financial records will be reconciled on a monthly basis by

the bookkeeper. The Financial Officer will review and approve reconciliations.
5. Federal grant funds will be drawn down on the 13th and 28th of each month to coincide with
the bimonthly payroll. Foundation and county funds provided under advance funding
agreements will be requested at the discretion of the project director, subject to review by the
Financial Officer, except where salary funds are needed for payroll purposes. For grants that
provide reimbursement funding, the Financial Officer will be responsible for tracking costs and
billing at appropriate times, but no less frequently than monthly unless the agreement stipulates
another time frame.
LESSON 7 | MODULE CAPSTONE: REVIEWING A SYSTEM AGAINST THE ADMINISTRATIVE
REQUIREMENTS
6. The Financial Officer is responsible for maintaining documentation of all expenditures. Staff
with purchasing authority shall follow procedures laid out in the Procurement Policy related to
submitting proper documentation to the Finance Officer for expenditures. If an account code
exists for the purchase, staff may categorize the purchase; however, if no code exists or if
category is unclear, the Financial Officer must decide the account code to use or create a new
account code.
7. The Financial Officer must approve all employee requests for advance or reimbursement.
Employee requests for reimbursement must be accompanied by receipts showing covered,
allowable activities. When advances are made, the employee receiving the advance must
submit receipts showing funds were spent for covered, allowable activities within fifteen (15)
working days after the covered activity. If any unspent funds remain, the employee must
reimburse the organization for the additional funds within fifteen working days after the covered
event. If the employee does not do so within this timeframe, the amount due will be deducted
from the employee's next paycheck.
8. The Financial Officer is also responsible for documenting all in-kind donations and volunteer
time (see also Volunteer Policy) and calculating fair market value of donated goods.
9. The Financial Officer is responsible for approving all financial reports required by sponsoring
agencies and organizations.
SUBTITLE I)
10. The Financial Officer is responsible for ensuring protecting personally identifiable information
on all financial records.
SUBTITLE I)
Action Planning
module.
Property Standards (2 CFR
200, Subpart D - Subtitle II)
MODULE 5 | PROPERTY STANDARDS (2 CFR 200, SUBPART D - SUBTITLE II)
PROPERTY STANDARDS (2 CFR 200,

SUBPART D - SUBTITLE II)
Module Objective
 Use 2 CFR 200, Subpart D, to locate needed information about property requirements
2 CFR 200 makes minor changes to the property standards under the administrative requirements.
The threshold for property to be treated as equipment remains at $5,000. The Uniform Guidance
uses the term "computing devices" to refer to technology such as computers, laptops, tablets, and
other electronic equipment.
SUBPART D - POST FEDERAL AWARD REQUIREMENTS - PROPERTY STANDARDS
Section Source New Provisions

Language
200.310 Insurance Coverage 2 CFR 215 Updated language now requires insurance coverage for federal property that has
been "improved with federal funds."
200.311 Real Property A-102 Updated language now includes real property that has been "improved under a
federal award."
200.312 Federally-Owned and Exempt 2 CFR 215 All non-federal entities must annually submit an inventory of federally owned
Property property.
200.313 Equipment A-102 Non-federal entities are required to use the FAIN on property records.
200.314 Supplies 2 CFR 215  Provides clarification on the treatment of computing devices; and
 Prevents all non-federal entities from charging other organizations a fee for
using supplies that is less than market price.
200.315 Intangible Property 2 CFR 215
200.316 Property Trust Relationship 2 CFR 215 All non-federal entities must hold all real property, equipment, and intangible
property acquired or improved with federal funds in a trust.
Activity: Property Standards
Answer the following questions by reviewing the Uniform

Guidance in Resource, 2 CFR 200: Uniform Guidance - Uniform
Administrative Requirements, Cost Principles, and Audit
Requirements. Identify the correct citation that relates to each
question.
1. Does your entity currently submit an annual inventory report

for federally-owned property?
2. Does your entity currently identify the FAIN for each piece of
property acquired or improved with federal funds?
3. Does your entity currently hold all property acquired or
improved with federal funds in a trust?
Lessons
1. Property Definitions
2. Property Management Standards
LESSON 1
PROPERTY DEFINITIONS
Lesson Objective
5.1.1 Apply the appropriate definitions to property items
1.1 PROPERTY AS DEFINED IN THE UNIFORM GUIDANCE
Categories of Property in the Uniform Guidance
The following is a list of property-related definitions used in the Uniform Guidance.

 Computing devices means machines used to acquire, store, analyze, process, and publish
data and other information electronically, including accessories (or “peripherals”) for printing,
transmitting and receiving, or storing electronic information. (§200.20 Computing Devices)
 Equipment means tangible personal property (including information technology systems)
having a useful life of more than one year and a per-unit acquisition cost which equals or
LESSON 1 | PROPERTY DEFINITIONS
exceeds the lesser of the capitalization level established by the non-Federal entity for financial
statement purposes, or $5,000. (§200.33 Equipment)
 General purpose equipment means equipment which is not limited to research, medical,
scientific or other technical activities. Examples include office equipment and furnishings,
modular offices, telephone networks, information technology equipment and systems, air
conditioning equipment, reproduction and printing equipment, and motor vehicles. (§200.48
General Purpose Equipment)
 Information technology systems means computing devices, ancillary equipment, software,
firmware, and similar procedures, services (including support services), and related resources.
(§200.58 Information Technology Systems)
 Intangible property means property having no physical existence, such as trademarks,
copyrights, patents and patent applications and property, such as loans, notes and other debt
instruments, lease agreements, stock and other instruments of property ownership (whether the
property is tangible or intangible). (§200.59 Intangible Property)
 Personal property means property other than real property. It may be tangible, having physical
existence, or intangible. (§200.78 Personal Property)
 Property means real property or personal property. (§200.81 Property)
 Real property means land, including land improvements, structures and appurtenances
thereto, but excludes moveable machinery and equipment. (§200.85 Real property)
 Special purpose equipment means equipment which is used only for research, medical,
scientific, or other technical activities. Examples of special purpose equipment include
microscopes, x-ray machines, surgical instruments, and spectrometers. (§200.89 Special
Purpose Equipment)
 Supplies means all tangible personal property other than those described in §200.33
Equipment. A computing device is a supply if the acquisition cost is less than the lesser of the
capitalization level established by the non-Federal entity for financial statement purposes or
$5,000, regardless of the length of its useful life. (§200.94 Supplies)
1.1.1 EXERCISE: APPLYING PROPERTY DEFINITIONS

Directions: For each group, select the correct term that identities the type of property for the item.
1. Select the correct category for the following items:

Real property Personal property
AP Government textbooks ☐ ☐
10 acres of land ☐ ☐
A practice gun range ☐ ☐
A laptop ☐ ☐

Tangible Intangible
property property
Textbooks purchased for participants in an ESL program run by a
nonprofit ☐ ☐
A patent for an invention developed under a federal grant ☐ ☐

Computer equipment used by a federally-funded research team to
record data from experiments ☐ ☐
The copyright for a textbook written under a Department of Education

grant ☐ ☐

Equipment Supplies
A $1,500 desktop computer
☐ ☐
A $25,000 truck
☐ ☐
A $7,500 television ☐ ☐
A $10 stapler ☐ ☐
LESSON 1 | PROPERTY DEFINITIONS
LESSON 2
PROPERTY MANAGEMENT STANDARDS
Lesson Objective
5.2.1 Identify standards for title, use, disposition, and insurance coverage of real and intangible
property, equipment, and supplies
Discussion
What types of properties have you had to manage personally on

your federal grant awards?
2.1 §200.310 INSURANCE COVERAGE

§200.310 Insurance coverage.
The non-Federal entity must, at a minimum, provide the

equivalent insurance coverage for real property and equipment
acquired or improved with Federal funds as provided to property
owned by the non-Federal entity. Federally-owned property
need not be insured unless required by the terms and conditions
of the Federal award.
LESSON 2 | PROPERTY MANAGEMENT STANDARDS
2.2 §200.311 REAL PROPERTY

§200.311 Real property.
(a) Title. Subject to the obligations and conditions set forth in

this section, title to real property acquired or improved under a
Federal award will vest upon acquisition in the non-Federal
entity.
(b) Use. Except as otherwise provided by Federal statutes or by

the Federal awarding agency, real property will be used for the
originally authorized purpose as long as needed for that
purpose, during which time the non-Federal entity must not
dispose of or encumber its title or other interests.
(c) Disposition. When real property is no longer needed for the

originally authorized purpose, the non-Federal entity must
obtain disposition instructions from the Federal awarding
agency or pass-through entity. The instructions must provide for
one of the following alternatives:
(1) Retain title after compensating the Federal awarding agency.

The amount paid to the Federal awarding agency will be
computed by applying the Federal awarding agency's
percentage of participation in the cost of the original purchase
(and costs of any improvements) to the fair market value of the
property. However, in those situations where the non-Federal
entity is disposing of real property acquired or improved with a
Federal award and acquiring replacement real property under
the same Federal award, the net proceeds from the disposition
may be used as an offset to the cost of the replacement
property.
(2) Sell the property and compensate the Federal awarding

agency. The amount due to the Federal awarding agency will be
calculated by applying the Federal awarding agency's
percentage of participation in the cost of the original purchase
(and cost of any improvements) to the proceeds of the sale after
deduction of any actual and reasonable selling and fixing-up
expenses. If the Federal award has not been closed out, the net
proceeds from sale may be offset against the original cost of the
property. When the non-Federal entity is directed to sell
property, sales procedures must be followed that provide for
competition to the extent practicable and result in the highest
possible return.
(3) Transfer title to the Federal awarding agency or to a third

party designated/approved by the Federal awarding agency.
The non-Federal entity is entitled to be paid an amount
calculated by applying the non-Federal entity's percentage of
participation in the purchase of the real property (and cost of
any improvements) to the current fair market value of the
property.
2.3 §200.312 FEDERALLY-OWNED AND EXEMPT PROPERTY

§200.312 Federally-owned and exempt property.
(a) Title to federally-owned property remains vested in the

Federal Government. The non-Federal entity must submit
annually an inventory listing of federally-owned property in its
custody to the Federal awarding agency. Upon completion of
the Federal award or when the property is no longer needed,
the non-Federal entity must report the property to the Federal
awarding agency for further Federal agency utilization.
(b) If the Federal awarding agency has no further need for the
property, it must declare the property excess and report it for
disposal to the appropriate Federal disposal authority, unless
the Federal awarding agency has statutory authority to dispose
of the property by alternative methods (e.g., the authority
provided by the Federal Technology Transfer Act (15 U.S.C.
3710 (i)) to donate research equipment to educational and non-
profit organizations in accordance with Executive Order 12999,
“Educational Technology: Ensuring Opportunity for All Children
in the Next Century.”). The Federal awarding agency must issue
appropriate instructions to the non-Federal entity.
(c) Exempt federally-owned property means property acquired

under a Federal award where the Federal awarding agency has
chosen to vest title to the property to the non-Federal entity
without further obligation to the Federal Government, based
upon the explicit terms and conditions of the Federal award. The
Federal awarding agency may exercise this option when
statutory authority exists. Absent statutory authority and specific
terms and conditions of the Federal award, title to exempt
federally-owned property acquired under the Federal award
remains with the Federal Government.
2.4 §200.313 EQUIPMENT

§200.313 Equipment.
See also §200.439 Equipment and other capital expenditures.
(a) Title. Subject to the obligations and conditions set forth in

this section, title to equipment acquired under a Federal award
will vest upon acquisition in the non-Federal entity. Unless a
statute specifically authorizes the Federal agency to vest title in
the non-Federal entity without further obligation to the Federal
Government, and the Federal agency elects to do so, the title
must be a conditional title. Title must vest in the non-Federal
entity subject to the following conditions:
(1) Use the equipment for the authorized purposes of the project
during the period of performance, or until the property is no
longer needed for the purposes of the project.
(2) Not encumber the property without approval of the Federal

awarding agency or pass-through entity.
(3) Use and dispose of the property in accordance with

paragraphs (b), (c) and (e) of this section.
(b) A state must use, manage and dispose of equipment

acquired under a Federal award by the state in accordance with
state laws and procedures. Other non-Federal entities must
follow paragraphs (c) through (e) of this section.
(c) Use. (1) Equipment must be used by the non-Federal entity

in the program or project for which it was acquired as long as
needed, whether or not the project or program continues to be
supported by the Federal award, and the non-Federal entity
must not encumber the property without prior approval of the
Federal awarding agency. When no longer needed for the
original program or project, the equipment may be used in other
activities supported by the Federal awarding agency, in the
following order of priority:
(i) Activities under a Federal award from the Federal awarding

agency which funded the original program or project, then
(ii) Activities under Federal awards from other Federal awarding

agencies. This includes consolidated equipment for information
technology systems.
(2) During the time that equipment is used on the project or

program for which it was acquired, the non-Federal entity must
also make equipment available for use on other projects or
programs currently or previously supported by the Federal
Government, provided that such use will not interfere with the
work on the projects or program for which it was originally
acquired. First preference for other use must be given to other
programs or projects supported by Federal awarding agency

that financed the equipment and second preference must be
given to programs or projects under Federal awards from other
Federal awarding agencies. Use for non-federally-funded
programs or projects is also permissible. User fees should be
considered if appropriate.
(3) Notwithstanding the encouragement in §200.307 Program

income to earn program income, the non-Federal entity must
not use equipment acquired with the Federal award to provide
services for a fee that is less than private companies charge for
equivalent services unless specifically authorized by Federal
statute for as long as the Federal Government retains an
interest in the equipment.
(4) When acquiring replacement equipment, the non-Federal

entity may use the equipment to be replaced as a trade-in or sell
the property and use the proceeds to offset the cost of the
replacement property.
(d) Management requirements. Procedures for managing

equipment (including replacement equipment), whether
acquired in whole or in part under a Federal award, until
disposition takes place will, as a minimum, meet the following
requirements:
(1) Property records must be maintained that include a

description of the property, a serial number or other
identification number, the source of funding for the property
(including the FAIN), who holds title, the acquisition date, and
cost of the property, percentage of Federal participation in the
project costs for the Federal award under which the property
was acquired, the location, use and condition of the property,
and any ultimate disposition data including the date of disposal
and sale price of the property.
(2) A physical inventory of the property must be taken and the

results reconciled with the property records at least once every
two years.
(3) A control system must be developed to ensure adequate

safeguards to prevent loss, damage, or theft of the property.
Any loss, damage, or theft must be investigated.
(4) Adequate maintenance procedures must be developed to

keep the property in good condition.
(5) If the non-Federal entity is authorized or required to sell the

property, proper sales procedures must be established to
ensure the highest possible return.
(e) Disposition. When original or replacement equipment

acquired under a Federal award is no longer needed for the
original project or program or for other activities currently or

previously supported by a Federal awarding agency, except as
otherwise provided in Federal statutes, regulations, or Federal
awarding agency disposition instructions, the non-Federal entity
must request disposition instructions from the Federal awarding
agency if required by the terms and conditions of the Federal
award. Disposition of the equipment will be made as follows, in
accordance with Federal awarding agency disposition
instructions:
(1) Items of equipment with a current per unit fair market value
of $5,000 or less may be retained, sold or otherwise disposed of
with no further obligation to the Federal awarding agency.
(2) Except as provided in §200.312 Federally-owned and

exempt property, paragraph (b), or if the Federal awarding
agency fails to provide requested disposition instructions within
120 days, items of equipment with a current per-unit fair-market
value in excess of $5,000 may be retained by the non-Federal
entity or sold. The Federal awarding agency is entitled to an
amount calculated by multiplying the current market value or
proceeds from sale by the Federal awarding agency's
percentage of participation in the cost of the original purchase. If
the equipment is sold, the Federal awarding agency may permit
the non-Federal entity to deduct and retain from the Federal
share $500 or ten percent of the proceeds, whichever is less, for
its selling and handling expenses.
(3) The non-Federal entity may transfer title to the property to

the Federal Government or to an eligible third party provided
that, in such cases, the non-Federal entity must be entitled to
compensation for its attributable percentage of the current fair
market value of the property.
(4) In cases where a non-Federal entity fails to take appropriate

disposition actions, the Federal awarding agency may direct the
non-Federal entity to take disposition actions.
EQUIPMENT DISPOSITION
2.5 §200.314 SUPPLIES

§200.314 Supplies.
See also §200.453 Materials and supplies costs, including costs

of computing devices.
(a) Title to supplies will vest in the non-Federal entity upon

acquisition. If there is a residual inventory of unused supplies
exceeding $5,000 in total aggregate value upon termination or
completion of the project or program and the supplies are not
needed for any other Federal award, the non-Federal entity
must retain the supplies for use on other activities or sell them,
but must, in either case, compensate the Federal government
for its share. The amount of compensation must be computed in
the same manner as for equipment. See §200.313 Equipment,
paragraph (e)(2) for the calculation methodology.
(b) As long as the Federal government retains an interest in the

supplies, the non-Federal entity must not use supplies acquired
under a Federal award to provide services to other
organizations for a fee that is less than private companies
charge for equivalent services, unless specifically authorized by
Federal statute.
2.6 §200.315 INTANGIBLE PROPERTY

§200.315 Intangible property.
(a) Title to intangible property (see §200.59 Intangible property)

acquired under a Federal award vests upon acquisition in the
non-Federal entity. The non-Federal entity must use that
property for the originally-authorized purpose, and must not
encumber the property without approval of the Federal awarding
agency. When no longer needed for the originally authorized
purpose, disposition of the intangible property must occur in
accordance with the provisions in §200.313 Equipment
paragraph (e).
(b) The non-Federal entity may copyright any work that is

subject to copyright and was developed, or for which ownership
was acquired, under a Federal award. The Federal awarding
agency reserves a royalty-free, nonexclusive and irrevocable
right to reproduce, publish, or otherwise use the work for
Federal purposes, and to authorize others to do so.
(c) The non-Federal entity is subject to applicable regulations

governing patents and inventions, including governmentwide
regulations issued by the Department of Commerce at 37 CFR
Part 401, “Rights to Inventions Made by Nonprofit Organizations
and Small Business Firms Under Government Awards,
Contracts and Cooperative Agreements.”
(d) The Federal Government has the right to:
(1) Obtain, reproduce, publish, or otherwise use the data

produced under a Federal award; and
(2) Authorize others to receive, reproduce, publish, or otherwise

use such data for Federal purposes.
(e) Freedom of Information Act (FOIA).
(1) In response to a Freedom of Information Act (FOIA) request

for research data relating to published research findings
produced under a Federal award that were used by the Federal
Government in developing an agency action that has the force
and effect of law, the Federal awarding agency must request,
and the non-Federal entity must provide, within a reasonable
time, the research data so that they can be made available to
the public through the procedures established under the FOIA. If
the Federal awarding agency obtains the research data solely in
response to a FOIA request, the Federal awarding agency may
charge the requester a reasonable fee equaling the full
incremental cost of obtaining the research data. This fee should
reflect costs incurred by the Federal agency and the non-
Federal entity. This fee is in addition to any fees the Federal
awarding agency may assess under the FOIA (5 U.S.C.
552(a)(4)(A)).
(2) Published research findings means when:
(i) Research findings are published in a peer-reviewed scientific

or technical journal; or
(ii) A Federal agency publicly and officially cites the research

findings in support of an agency action that has the force and
effect of law. “Used by the Federal Government in developing
an agency action that has the force and effect of law” is defined
as when an agency publicly and officially cites the research
findings in support of an agency action that has the force and
effect of law.
(3) Research data means the recorded factual material

commonly accepted in the scientific community as necessary to
validate research findings, but not any of the following:
preliminary analyses, drafts of scientific papers, plans for future
research, peer reviews, or communications with colleagues.
This “recorded” material excludes physical objects (e.g.,
laboratory samples). Research data also do not include:
(i) Trade secrets, commercial information, materials necessary

to be held confidential by a researcher until they are published,
or similar information which is protected under law; and
(ii) Personnel and medical information and similar information

the disclosure of which would constitute a clearly unwarranted
invasion of personal privacy, such as information that could be
used to identify a particular person in a research study.
2.7 §200.316 PROPERTY TRUST RELATIONSHIPS

§200.316 Property trust relationship.
Real property, equipment, and intangible property, that are

acquired or improved with a Federal award must be held in trust
by the non-Federal entity as trustee for the beneficiaries of the
project or program under which the property was acquired or
improved. The Federal awarding agency may require the non-
Federal entity to record liens or other appropriate notices of
record to indicate that personal or real property has been
acquired or improved with a Federal award and that use and
disposition conditions apply to the property.
Discussion
How do you ensure the FAIN is associated with each piece of

property acquired under federal awards?
2.8 EXERCISE: ADMINISTRATION OF PROPERTY TYPES

Overview
Work as a team to read and summarize the property provisions in the Uniform Guidance
Directions
Summarize the treatment of each property type. Include the appropriate citations.
Title Use Disposition
Real
Property
Equipment
Supplies
Intangible
Property
Action Planning
module.
Procurement Standards (2
Subtitle III)
MODULE 6 | PROCUREMENT STANDARDS (2 CFR 200, SUBPART D - SUBTITLE III)
PROCUREMENT STANDARDS (2 CFR

200, SUBPART D - SUBTITLE III)
Module Objective
 Use 2 CFR 200, Subpart D, to locate needed information about procurement requirements
2 CFR 200 made significant changes to the procurement standards. The Uniform Guidance
predominately used language from OMB Circular A-102 for this subtitle and modified previous
procurement standards. This subtitle required significant attention by non-federal entities that
frequently procure using federal funds, especially those non-federal entities with little experience
with OMB Circular A-102. To provide non-federal entities maximum flexibility, OMB instituted a
three-year grace period to comply with this subtitle. Under 2 CFR 200.110(a), non-federal entities
that opt for the three-year grace period are required to document this decision in their internal
procurement policies.
2 CFR 200 created a new procurement method, the micro-purchase method, designed to reduce
administrative burdens. Another requirement change affected the Simplified Acquisition Threshold.
The Uniform Guidance tied all future increase of the Simplified Acquisition Threshold to the FAR.
SUBPART D - POST FEDERAL AWARD REQUIREMENTS - PROCUREMENT STANDARDS
§200.317 Procurements by states A-102
§200.318 General procurement 2 CFR 215  Requires all non-federal entities maintain an organizational conflict of interest
standards policy
 Requires all non-federal entities maintain records regarding the selection
process for all contracts
 Allows all non-federal entities to use time and material (T&M) type contracts
§200.319 Competition A-102  Provides a list of prohibited actions that limit competition
 Prohibits all non-federal entities from providing geographical preference in
the evaluation of bids and proposals
 All non-federal entities are prohibited from precluding potential bidders from
qualifying in the solicitation period
§200.320 Methods of procurement to be A-102  Creates the micro-purchase procurement method

followed  Ties the SImplified Acquisition Threshold to the FAR
 Provides detailed information regarding procurement methods
§200.321 Contracting with small and A-102 Identifies steps all non-federal entities must take to provide maximum
minority businesses, women's business opportunities for minority- and women-owned businesses and small businesses.
enterprises, and labor surplus area firms
§200.322 Procurement of recovered A-102

materials
§200.323 Contract cost and price A-102
§200.324 Federal awarding agency or A-102

pass-through entity review
§200.325 Bonding requirements A-102
§200.326 Contract provisions A-102 Removes contract provisions related to the Energy Policy and Conservation Act.
Lessons
1. Procurements by States
2. Procurements by Others
3. Contract Provisions
4. Module Capstone: Revising Procurement Policies
LESSON 1
PROCUREMENTS BY STATES
Lesson Objective
6.1.1 Explain the procurement policies that states must follow
Discussion
Poll: By a show of hands:

 How many of you work with state requirements for
procurement today?
 How many of you have worked with state requirements for
procurement in the past?
1.1 §200.317 PROCUREMENTS BY STATES
States and Non-States Requirements for Procurement
§200.317 Procurements by states.
When procuring property and services under a Federal award, a

state must follow the same policies and procedures it uses for
procurements from its non-Federal funds. The state will comply
with §200.322 Procurement of recovered materials and ensure
that every purchase order or other contract includes any clauses
required by section §200.326 Contract provisions. All other non-
Federal entities, including subrecipients of a state, will follow
§200.318 General procurement standards through 200.326
Contract provisions.
LESSON 1 | PROCUREMENTS BY STATES
2 CFR 200.90 defines a state as "any state of the United States, the District of Columbia, the
Commonwealth of Puerto Rico, U.S. Virgin Islands, Guam, American Samoa, the Commonwealth of
the Northern Mariana Islands, and any agency or instrumentality thereof exclusive of local
governments.”
The following table summarizes the procurement policies for non-federal entities.
Non-Federal Entity Type Procurement Policies
State governments  State law (see 2 CFR 200.317)

 2 CFR 200.322 Procurement of recovered
materials
 2 CFR 200.326 Contract provisions
Local governments, Indian tribes, non-profit 2 CFR 200.318 to 2 CFR 200.326

organizations, IHEs, and hospitals
LESSON 2
PROCUREMENTS BY OTHERS
Lesson Objective
6.2.1 Explain the procurement policies that all entities, except states, must follow
Discussion

 How many of you work with non-state entity requirements for
procurement today?
 How many of you have worked with non-state entity
requirements for procurement in the past?
2.1 §200.318 GENERAL PROCUREMENT STANDARDS
Non-States Requirements for Procurement
LESSON 2 | PROCUREMENTS BY OTHERS
§200.318 General procurement standards.
(a) The non-Federal entity must use its own documented

procurement procedures which reflect applicable State, local,
and tribal laws and regulations, provided that the procurements
conform to applicable Federal law and the standards identified
in this part.
(b) Non-Federal entities must maintain oversight to ensure that

contractors perform in accordance with the terms, conditions,
and specifications of their contracts or purchase orders.
(c)(1) The non-Federal entity must maintain written standards of

conduct covering conflicts of interest and governing the actions
of its employees engaged in the selection, award and
administration of contracts. No employee, officer, or agent may
participate in the selection, award, or administration of a
contract supported by a Federal award if he or she has a real or
apparent conflict of interest. Such a conflict of interest would
arise when the employee, officer, or agent, any member of his
or her immediate family, his or her partner, or an organization
which employs or is about to employ any of the parties indicated
herein, has a financial or other interest in or a tangible personal
benefit from a firm considered for a contract. The officers,
employees, and agents of the non-Federal entity may neither
solicit nor accept gratuities, favors, or anything of monetary
value from contractors or parties to subcontracts. However, non-
Federal entities may set standards for situations in which the
financial interest is not substantial or the gift is an unsolicited
item of nominal value. The standards of conduct must provide
for disciplinary actions to be applied for violations of such
standards by officers, employees, or agents of the non-Federal
entity.
(2) If the non-Federal entity has a parent, affiliate, or subsidiary

organization that is not a state, local government, or Indian tribe,
the non-Federal entity must also maintain written standards of
conduct covering organizational conflicts of interest.
Organizational conflicts of interest means that because of
relationships with a parent company, affiliate, or subsidiary
organization, the non-Federal entity is unable or appears to be
unable to be impartial in conducting a procurement action
involving a related organization.
(d) The non-Federal entity's procedures must avoid acquisition

of unnecessary or duplicative items. Consideration should be
given to consolidating or breaking out procurements to obtain a
more economical purchase. Where appropriate, an analysis will
be made of lease versus purchase alternatives, and any other
appropriate analysis to determine the most economical
approach.
(e) To foster greater economy and efficiency, and in accordance

with efforts to promote cost-effective use of shared services
across the Federal Government, the non-Federal entity is
encouraged to enter into state and local intergovernmental
agreements or inter-entity agreements where appropriate for
procurement or use of common or shared goods and services.
(f) The non-Federal entity is encouraged to use Federal excess

and surplus property in lieu of purchasing new equipment and
property whenever such use is feasible and reduces project
costs.
(g) The non-Federal entity is encouraged to use value

engineering clauses in contracts for construction projects of
sufficient size to offer reasonable opportunities for cost
reductions. Value engineering is a systematic and creative
analysis of each contract item or task to ensure that its essential
function is provided at the overall lower cost.
(h) The non-Federal entity must award contracts only to

responsible contractors possessing the ability to perform
successfully under the terms and conditions of a proposed
procurement. Consideration will be given to such matters as
contractor integrity, compliance with public policy, record of past
performance, and financial and technical resources. See also
§200.213 Suspension and debarment.
(i) The non-Federal entity must maintain records sufficient to

detail the history of procurement. These records will include, but
are not necessarily limited to the following: rationale for the
method of procurement, selection of contract type, contractor
selection or rejection, and the basis for the contract price.
(j)(1) The non-Federal entity may use a time and materials type
contract only after a determination that no other contract is
suitable and if the contract includes a ceiling price that the
contractor exceeds at its own risk. Time and materials type
contract means a contract whose cost to a non-Federal entity is
the sum of:
(i) The actual cost of materials; and
(ii) Direct labor hours charged at fixed hourly rates that reflect
wages, general and administrative expenses, and profit.
(2) Since this formula generates an open-ended contract price,

a time-and-materials contract provides no positive profit
incentive to the contractor for cost control or labor efficiency.
Therefore, each contract must set a ceiling price that the
contractor exceeds at its own risk. Further, the non-Federal
entity awarding such a contract must assert a high degree of
oversight in order to obtain reasonable assurance that the
contractor is using efficient methods and effective cost controls.
(k) The non-Federal entity alone must be responsible, in

accordance with good administrative practice and sound
business judgment, for the settlement of all contractual and
administrative issues arising out of procurements. These issues
include, but are not limited to, source evaluation, protests,
disputes, and claims. These standards do not relieve the non-
Federal entity of any contractual responsibilities under its
contracts. The Federal awarding agency will not substitute its
judgment for that of the non-Federal entity unless the matter is
primarily a Federal concern. Violations of law will be referred to
the local, state, or Federal authority having proper jurisdiction.
A non-federal entity's procurement policies must adhere to applicable state and local laws. 1 When
there is a conflict between federal law, regulation, or rule (including provisions found in the Uniform
Guidance) and state or local law, the non-federal entity must follow the federal law, regulation, or
rule. A recipient should refer questions to legal counsel or to the awarding agency when a conflict
arises.
The Uniform Guidance requires non-federal entities develop and maintain written standards to
prevent conflict of interest in the selection, awarding, and administration of contracts. The standards
must also include a section that details the disciplinary consequences for employees and
contractors found in violation of the conflict of interest policy. Additionally, non-federal entities must
also adopt standards governing organizational conflicts of interest.
Non-federal entities are also required to award contracts only to individuals and firms that are
capable of successfully meeting the terms and conditions of the contract. The Uniform Guidance
states that non-federal entities should consider a contractor's past performance, integrity, and
financial and technical resources. Though not discussed in 2 CFR 200.318, non-federal entities
should be aware of their responsibility to verify that a contractor is not debarred or suspended by
checking the Exclusion Extract on SAM.gov.
2 CFR 200.318(i) requires non-federal entities to maintain records regarding the selection and
awarding of contracts. Under previous guidance, IHEs, hospitals, and non-profit organizations were
only required to maintain detailed records for contracts that exceeded the Simplified Acquisition
Threshold.
1
2 CFR 200.317 requires states to follow their own procurement laws, therefore, states do not follow 2 CFR 200.318 to 2
CFR 200.321, and 2 CFR 200.323 to 2 CFR 200.325. For these sections, the phrase "non-federal entities" refers to all
non-federal entities, except states.
2 CFR 200.110(a) provides non-federal entities a three-year grace period to implement changes to
their internal procurement policies. If a non-federal entity decides to use the grace period, then the
non-federal entity must update internal policies to reflect this decision.
2.2 §200.319 COMPETITION
2 CFR 200.319 Prohibitions
§200.319 Competition.
(a) All procurement transactions must be conducted in a manner

providing full and open competition consistent with the
standards of this section. In order to ensure objective contractor
performance and eliminate unfair competitive advantage,
contractors that develop or draft specifications, requirements,
statements of work, or invitations for bids or requests for
proposals must be excluded from competing for such
procurements. Some of the situations considered to be
restrictive of competition include but are not limited to:
(1) Placing unreasonable requirements on firms in order for

them to qualify to do business;
(2) Requiring unnecessary experience and excessive bonding;
(3) Noncompetitive pricing practices between firms or between

affiliated companies;
(4) Noncompetitive contracts to consultants that are on retainer

contracts;
(5) Organizational conflicts of interest;
(6) Specifying only a “brand name” product instead of allowing

“an equal” product to be offered and describing the performance
or other relevant requirements of the procurement; and
(7) Any arbitrary action in the procurement process.
(b) The non-Federal entity must conduct procurements in a

manner that prohibits the use of statutorily or administratively
imposed state, local, or tribal geographical preferences in the
evaluation of bids or proposals, except in those cases where
applicable Federal statutes expressly mandate or encourage
geographic preference. Nothing in this section preempts state
licensing laws. When contracting for architectural and
engineering (A/E) services, geographic location may be a
selection criterion provided its application leaves an appropriate
number of qualified firms, given the nature and size of the
project, to compete for the contract.
(c) The non-Federal entity must have written procedures for

procurement transactions. These procedures must ensure that
all solicitations:
(1) Incorporate a clear and accurate description of the technical

requirements for the material, product, or service to be
procured. Such description must not, in competitive
procurements, contain features which unduly restrict
competition. The description may include a statement of the
qualitative nature of the material, product or service to be
procured and, when necessary, must set forth those minimum

essential characteristics and standards to which it must conform
if it is to satisfy its intended use. Detailed product specifications
should be avoided if at all possible. When it is impractical or
uneconomical to make a clear and accurate description of the
technical requirements, a “brand name or equivalent”
description may be used as a means to define the performance
or other salient requirements of procurement. The specific
features of the named brand which must be met by offers must
be clearly stated; and
(2) Identify all requirements which the offerors must fulfill and all
other factors to be used in evaluating bids or proposals.
(d) The non-Federal entity must ensure that all prequalified lists
of persons, firms, or products which are used in acquiring goods
and services are current and include enough qualified sources
to ensure maximum open and free competition. Also, the non-
Federal entity must not preclude potential bidders from
qualifying during the solicitation period.
Non-federal entities procuring services and property with federal awards must ensure the contract
award process is fair for all potential bidders. 2 CFR 200.319 identifies situations that limit
competition. Non-federal entities are prohibited in engaging in any of the identified practices. The
provided list is not all-inclusive.
The Uniform Guidance contains a provision, found at 200.319(b), that prohibits non-federal entities
from providing geographical preference in the evaluation of bids or proposals. This provision was
previously found in A-102, but not 2 CFR 215. When there is a conflict between state or tribal law
and this provision, the provision in the Uniform Guidance prevails. This provision does not apply to
state governments.
2.3 §200.320 METHODS OF PROCUREMENT TO BE FOLLOWED

§200.320 Methods of procurement to be followed.
The non-Federal entity must use one of the following methods

of procurement.
(a) Procurement by micro-purchases. Procurement by micro-

purchase is the acquisition of supplies or services, the
aggregate dollar amount of which does not exceed the micro-
purchase threshold (§200.67 Micro-purchase). To the extent
practicable, the non-Federal entity must distribute micro-
purchases equitably among qualified suppliers. Micro-purchases
may be awarded without soliciting competitive quotations if the
non-Federal entity considers the price to be reasonable.
(b) Procurement by small purchase procedures. Small purchase

procedures are those relatively simple and informal
procurement methods for securing services, supplies, or other
property that do not cost more than the Simplified Acquisition
Threshold. If small purchase procedures are used, price or rate
quotations must be obtained from an adequate number of
qualified sources.
(c) Procurement by sealed bids (formal advertising). Bids are

publicly solicited and a firm fixed price contract (lump sum or
unit price) is awarded to the responsible bidder whose bid,
conforming with all the material terms and conditions of the
invitation for bids, is the lowest in price. The sealed bid method
is the preferred method for procuring construction, if the
conditions in paragraph (c)(1) of this section apply.
(1) In order for sealed bidding to be feasible, the following

conditions should be present:
(i) A complete, adequate, and realistic specification or purchase

description is available;
(ii) Two or more responsible bidders are willing and able to

compete effectively for the business; and
(iii) The procurement lends itself to a firm fixed price contract

and the selection of the successful bidder can be made
principally on the basis of price.
(2) If sealed bids are used, the following requirements apply:
(i) Bids must be solicited from an adequate number of known

suppliers, providing them sufficient response time prior to the
date set for opening the bids, for local, and tribal governments,
the invitation for bids must be publicly advertised;
(ii) The invitation for bids, which will include any specifications
and pertinent attachments, must define the items or services in
order for the bidder to properly respond;
(iii) All bids will be opened at the time and place prescribed in
the invitation for bids, and for local and tribal governments, the
bids must be opened publicly;
(iv) A firm fixed price contract award will be made in writing to

the lowest responsive and responsible bidder. Where specified
in bidding documents, factors such as discounts, transportation
cost, and life cycle costs must be considered in determining
which bid is lowest. Payment discounts will only be used to
determine the low bid when prior experience indicates that such
discounts are usually taken advantage of; and
(v) Any or all bids may be rejected if there is a sound

documented reason.
(d) Procurement by competitive proposals. The technique of

competitive proposals is normally conducted with more than one
source submitting an offer, and either a fixed price or cost-
reimbursement type contract is awarded. It is generally used
when conditions are not appropriate for the use of sealed bids. If
this method is used, the following requirements apply:
(1) Requests for proposals must be publicized and identify all

evaluation factors and their relative importance. Any response
to publicized requests for proposals must be considered to the
maximum extent practical;
(2) Proposals must be solicited from an adequate number of

qualified sources;
(3) The non-Federal entity must have a written method for

conducting technical evaluations of the proposals received and
for selecting recipients;
(4) Contracts must be awarded to the responsible firm whose

proposal is most advantageous to the program, with price and
other factors considered; and
(5) The non-Federal entity may use competitive proposal

procedures for qualifications-based procurement of
architectural/engineering (A/E) professional services whereby
competitors' qualifications are evaluated and the most qualified
competitor is selected, subject to negotiation of fair and
reasonable compensation. The method, where price is not used
as a selection factor, can only be used in procurement of A/E
professional services. It cannot be used to purchase other types
of services though A/E firms are a potential source to perform
the proposed effort.
(e) [Reserved]
(f) Procurement by noncompetitive proposals. Procurement by

noncompetitive proposals is procurement through solicitation of
a proposal from only one source and may be used only when
one or more of the following circumstances apply:
(1) The item is available only from a single source;
(2) The public exigency or emergency for the requirement will

not permit a delay resulting from competitive solicitation;
(3) The Federal awarding agency or pass-through entity

expressly authorizes noncompetitive proposals in response to a
written request from the non-Federal entity; or
(4) After solicitation of a number of sources, competition is

determined inadequate.
Methods of Procurement
The Uniform Guidance identifies and explains five methods non-federal entities may use to procure
property and services under federal awards.
 Micro-Purchases. This method may be used to obtain supplies and services that are valued at
less than $10,000. This method can be used to expedite the procurement process by allowing
non-federal entities to obtain necessary supplies without issuing formal procurement
solicitations. While non-federal entities do not have to request quotes for these type of
purchases, it will still be necessary to retain all receipts for accounting purposes.
In anticipation of changes to the FAR, OMB issued a memo raising the

micro-purchase threshold from $3,500 to $10,000 effective June 21, 2018.
The micro-purchase threshold for construction acquisitions subject to the
Davis-Bacon Act remains at $2,000 by statute.
Refer to Resource
M-18-18: Memorandum For Chief Financial Officers and Heads

of Small Executive Agencies
 Small Purchases. This method is used to obtain items valued at less than the Simplified
Acquisition Threshold.2 When using this method, non-federal entities must obtain price and rate
quotations from an adequate number of qualified sources before awarding a contract.
 Sealed Bids. This is the preferred method of awarding construction contracts. The only
selection criteria in awarding a contract is the bid amount, and the contract must be awarded to
the lowest bidder.
 Competitive Proposals. Non-federal entities may use this method when conditions are not
appropriate for sealed bids. Non-federal entities must establish and publish written procedures
that will be used to evaluate bids.
 Noncompetitive Proposals. A non-federal entity may make a noncompetitive award for any
amount, however, the non-federal entity must comply with requirements found at 2 CFR
200.320(f). Non-federal entities must ensure that proper documentation, as identified at Section
200.318(i), is contained in the procurement records when a noncompetitive contract is awarded.
Failure to adequately justify and document a noncompetitive contract may result in an audit
finding, a disallowance, and/or legal ramifications.
2
At §200.88, the Uniform Guidance aligns the Simplified Acquisition Threshold to the Federal Acquisition Regulation
(FAR).
2.4 §200.321 CONTRACTING WITH SMALL AND MINORITY

BUSINESSES, WOMEN'S BUSINESS ENTERPRISES, AND LABOR
SURPLUS AREA FIRMS
Small and Minority Businesses, Women's Business Enterprises, and Labor Surplus Area Firms
§200.321 Contracting with small and minority businesses,

women's business enterprises, and labor surplus area
firms.
(a) The non-Federal entity must take all necessary affirmative

steps to assure that minority businesses, women's business
enterprises, and labor surplus area firms are used when
possible.
(b) Affirmative steps must include:
(1) Placing qualified small and minority businesses and

women's business enterprises on solicitation lists;
(2) Assuring that small and minority businesses, and women's

business enterprises are solicited whenever they are potential
sources;
(3) Dividing total requirements, when economically feasible, into

smaller tasks or quantities to permit maximum participation by
small and minority businesses, and women's business
enterprises;
(4) Establishing delivery schedules, where the requirement

permits, which encourage participation by small and minority
businesses, and women's business enterprises;
(5) Using the services and assistance, as appropriate, of such

organizations as the Small Business Administration and the
Minority Business Development Agency of the Department of
Commerce; and
(6) Requiring the prime contractor, if subcontracts are to be let,

to take the affirmative steps listed in paragraphs (1) through (5)
of this section.
2.5 §200.322 PROCUREMENT OF RECOVERED MATERIALS
States and Non-States Requirements for Procurement
§200.322 Procurement of recovered materials.
A non-Federal entity that is a state agency or agency of a

political subdivision of a state and its contractors must comply
with section 6002 of the Solid Waste Disposal Act, as amended
by the Resource Conservation and Recovery Act. The
requirements of Section 6002 include procuring only items
designated in guidelines of the Environmental Protection
Agency (EPA) at 40 CFR part 247 that contain the highest
percentage of recovered materials practicable, consistent with
maintaining a satisfactory level of competition, where the
purchase price of the item exceeds $10,000 or the value of the
quantity acquired during the preceding fiscal year exceeded
$10,000; procuring solid waste management services in a
manner that maximizes energy and resource recovery; and
establishing an affirmative procurement program for
procurement of recovered materials identified in the EPA
guidelines.
2.6 §200.323 CONTRACT COST AND PRICE

§200.323 Contract cost and price.
(a) The non-Federal entity must perform a cost or price analysis

in connection with every procurement action in excess of the
Simplified Acquisition Threshold including contract
modifications. The method and degree of analysis is dependent
on the facts surrounding the particular procurement situation,
but as a starting point, the non-Federal entity must make
independent estimates before receiving bids or proposals.
(b) The non-Federal entity must negotiate profit as a separate

element of the price for each contract in which there is no price
competition and in all cases where cost analysis is performed.
To establish a fair and reasonable profit, consideration must be
given to the complexity of the work to be performed, the risk
borne by the contractor, the contractor's investment, the amount
of subcontracting, the quality of its record of past performance,
and industry profit rates in the surrounding geographical area for
similar work.
(c) Costs or prices based on estimated costs for contracts under

the Federal award are allowable only to the extent that costs
incurred or cost estimates included in negotiated prices would
be allowable for the non-Federal entity under Subpart E—Cost
Principles of this part. The non-Federal entity may reference its
own cost principles that comply with the Federal cost principles.
(d) The cost plus a percentage of cost and percentage of

construction cost methods of contracting must not be used.
Price Analysis Cost Analysis
 Examines the total price under consideration as  Breaks down total price into individual cost
the single pricing factor elements (e.g., labor, equipment, material)
 Compares the total price to comparable  Reviews and evaluates each individual element
measures/units  Performed only when justified by the nature of
 Used to determine that the overall price is the situation and/or significant dollar values
reasonable
2.7 §200.324 FEDERAL AWARDING AGENCY OR PASS-THROUGH

ENTITY REVIEW
§200.324 Federal awarding agency or pass-through entity
review.
(a) The non-Federal entity must make available, upon request of

the Federal awarding agency or pass-through entity, technical
specifications on proposed procurements where the Federal
awarding agency or pass-through entity believes such review is
needed to ensure that the item or service specified is the one
being proposed for acquisition. This review generally will take
place prior to the time the specification is incorporated into a
solicitation document. However, if the non-Federal entity desires
to have the review accomplished after a solicitation has been
developed, the Federal awarding agency or pass-through entity
may still review the specifications, with such review usually
limited to the technical aspects of the proposed purchase.
(b) The non-Federal entity must make available upon request,

for the Federal awarding agency or pass-through entity pre-
procurement review, procurement documents, such as requests
for proposals or invitations for bids, or independent cost
estimates, when:
(1) The non-Federal entity's procurement procedures or

operation fails to comply with the procurement standards in this
part;
(2) The procurement is expected to exceed the Simplified

Acquisition Threshold and is to be awarded without competition
or only one bid or offer is received in response to a solicitation;
(3) The procurement, which is expected to exceed the Simplified

Acquisition Threshold, specifies a “brand name” product;
(4) The proposed contract is more than the Simplified

Acquisition Threshold and is to be awarded to other than the
apparent low bidder under a sealed bid procurement; or
(5) A proposed contract modification changes the scope of a

contract or increases the contract amount by more than the
Simplified Acquisition Threshold.
(c) The non-Federal entity is exempt from the pre-procurement

review in paragraph (b) of this section if the Federal awarding
agency or pass-through entity determines that its procurement
systems comply with the standards of this part.
(1) The non-Federal entity may request that its procurement

system be reviewed by the Federal awarding agency or pass-
through entity to determine whether its system meets these
standards in order for its system to be certified. Generally, these
reviews must occur where there is continuous high-dollar
funding, and third party contracts are awarded on a regular
basis;
(2) The non-Federal entity may self-certify its procurement

system. Such self-certification must not limit the Federal
awarding agency's right to survey the system. Under a self-
certification procedure, the Federal awarding agency may rely
on written assurances from the non-Federal entity that it is
complying with these standards. The non-Federal entity must
cite specific policies, procedures, regulations, or standards as
being in compliance with these requirements and have its
system available for review.
2.8 §200.325 BONDING REQUIREMENTS

§200.325 Bonding requirements.
For construction or facility improvement contracts or

subcontracts exceeding the Simplified Acquisition Threshold,
the Federal awarding agency or pass-through entity may accept
the bonding policy and requirements of the non-Federal entity
provided that the Federal awarding agency or pass-through
entity has made a determination that the Federal interest is
adequately protected. If such a determination has not been
made, the minimum requirements must be as follows:
(a) A bid guarantee from each bidder equivalent to five percent

of the bid price. The “bid guarantee” must consist of a firm
commitment such as a bid bond, certified check, or other
negotiable instrument accompanying a bid as assurance that
the bidder will, upon acceptance of the bid, execute such
contractual documents as may be required within the time
specified.
(b) A performance bond on the part of the contractor for 100

percent of the contract price. A “performance bond” is one
executed in connection with a contract to secure fulfillment of all
the contractor's obligations under such contract.
(c) A payment bond on the part of the contractor for 100 percent
of the contract price. A “payment bond” is one executed in
connection with a contract to assure payment as required by law
of all persons supplying labor and material in the execution of
the work provided for in the contract.
LESSON 3
CONTRACT PROVISIONS
Lesson Objective
6.3.1 Identify applicable contract provisions
3.1 §200.326 CONTRACT PROVISIONS AND APPENDIX II TO 2 CFR

200
§200.326 Contract provisions.
The non-Federal entity's contracts must contain the applicable
provisions described in Appendix II to Part 200—Contract
Provisions for non-Federal Entity Contracts Under Federal
Awards.
LESSON 3 | CONTRACT PROVISIONS
Appendix II to Part 200—Contract Provisions for Non-

Federal Entity Contracts Under Federal Awards
In addition to other provisions required by the Federal agency or

non-Federal entity, all contracts made by the non-Federal entity
under the Federal award must contain provisions covering the
following, as applicable.
(A) Contracts for more than the simplified acquisition threshold

currently set at $150,000, which is the inflation adjusted amount
determined by the Civilian Agency Acquisition Council and the
Defense Acquisition Regulations Council (Councils) as
authorized by 41 U.S.C. 1908, must address administrative,
contractual, or legal remedies in instances where contractors
violate or breach contract terms, and provide for such sanctions
and penalties as appropriate.
(B) All contracts in excess of $10,000 must address termination

for cause and for convenience by the non-Federal entity
including the manner by which it will be effected and the basis
for settlement.
(C) Equal Employment Opportunity. Except as otherwise

provided under 41 CFR Part 60, all contracts that meet the
definition of “federally assisted construction contract” in 41 CFR
Part 60-1.3 must include the equal opportunity clause provided
under 41 CFR 60-1.4(b), in accordance with Executive Order
11246, “Equal Employment Opportunity” (30 FR 12319, 12935,
3 CFR Part, 1964-1965 Comp., p. 339), as amended by
Executive Order 11375, “Amending Executive Order 11246
Relating to Equal Employment Opportunity,” and implementing
regulations at 41 CFR part 60, “Office of Federal Contract
Compliance Programs, Equal Employment Opportunity,
Department of Labor.”
(D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148).

When required by Federal program legislation, all prime
construction contracts in excess of $2,000 awarded by non-
Federal entities must include a provision for compliance with the
Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as
supplemented by Department of Labor regulations (29 CFR Part
5, “Labor Standards Provisions Applicable to Contracts
Covering Federally Financed and Assisted Construction”). In
accordance with the statute, contractors must be required to pay
wages to laborers and mechanics at a rate not less than the
prevailing wages specified in a wage determination made by the
Secretary of Labor. In addition, contractors must be required to
pay wages not less than once a week. The non-Federal entity
must place a copy of the current prevailing wage determination
issued by the Department of Labor in each solicitation. The
decision to award a contract or subcontract must be conditioned
upon the acceptance of the wage determination. The non-
Federal entity must report all suspected or reported violations to
the Federal awarding agency. The contracts must also include a

provision for compliance with the Copeland “Anti-Kickback” Act
(40 U.S.C. 3145), as supplemented by Department of Labor
regulations (29 CFR Part 3, “Contractors and Subcontractors on
Public Building or Public Work Financed in Whole or in Part by
Loans or Grants from the United States”). The Act provides that
each contractor or subrecipient must be prohibited from
inducing, by any means, any person employed in the
construction, completion, or repair of public work, to give up any
part of the compensation to which he or she is otherwise
entitled. The non-Federal entity must report all suspected or
reported violations to the Federal awarding agency.
(E) Contract Work Hours and Safety Standards Act (40 U.S.C.
3701-3708). Where applicable, all contracts awarded by the
non-Federal entity in excess of $100,000 that involve the
employment of mechanics or laborers must include a provision
for compliance with 40 U.S.C. 3702 and 3704, as supplemented
by Department of Labor regulations (29 CFR Part 5). Under 40
U.S.C. 3702 of the Act, each contractor must be required to
compute the wages of every mechanic and laborer on the basis
of a standard work week of 40 hours. Work in excess of the
standard work week is permissible provided that the worker is
compensated at a rate of not less than one and a half times the
basic rate of pay for all hours worked in excess of 40 hours in
the work week. The requirements of 40 U.S.C. 3704 are
applicable to construction work and provide that no laborer or
mechanic must be required to work in surroundings or under
working conditions which are unsanitary, hazardous or
dangerous. These requirements do not apply to the purchases
of supplies or materials or articles ordinarily available on the
open market, or contracts for transportation or transmission of
intelligence.
(F) Rights to Inventions Made Under a Contract or Agreement. If

the Federal award meets the definition of “funding agreement”
under 37 CFR §401.2 (a) and the recipient or subrecipient
wishes to enter into a contract with a small business firm or
nonprofit organization regarding the substitution of parties,
assignment or performance of experimental, developmental, or
research work under that “funding agreement,” the recipient or
subrecipient must comply with the requirements of 37 CFR Part
401, “Rights to Inventions Made by Nonprofit Organizations and
Small Business Firms Under Government Grants, Contracts and
Cooperative Agreements,” and any implementing regulations
issued by the awarding agency.
(G) Clean Air Act (42 U.S.C. 7401-7671q.) and the Federal
Water Pollution Control Act (33 U.S.C. 1251-1387), as
amended—Contracts and subgrants of amounts in excess of
$150,000 must contain a provision that requires the non-Federal
award to agree to comply with all applicable standards, orders
or regulations issued pursuant to the Clean Air Act (42 U.S.C.
7401-7671q) and the Federal Water Pollution Control Act as

amended (33 U.S.C. 1251-1387). Violations must be reported to
the Federal awarding agency and the Regional Office of the
Environmental Protection Agency (EPA).
(H) Debarment and Suspension (Executive Orders 12549 and

12689)—A contract award (see 2 CFR 180.220) must not be
made to parties listed on the governmentwide exclusions in the
System for Award Management (SAM), in accordance with the
OMB guidelines at 2 CFR 180 that implement Executive Orders
12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part
1989 Comp., p. 235), “Debarment and Suspension.” SAM
Exclusions contains the names of parties debarred, suspended,
or otherwise excluded by agencies, as well as parties declared
ineligible under statutory or regulatory authority other than
Executive Order 12549.
(I) Byrd Anti-Lobbying Amendment (31 U.S.C. 1352)—

Contractors that apply or bid for an award exceeding $100,000
must file the required certification. Each tier certifies to the tier
above that it will not and has not used Federal appropriated
funds to pay any person or organization for influencing or
attempting to influence an officer or employee of any agency, a
member of Congress, officer or employee of Congress, or an
employee of a member of Congress in connection with obtaining
any Federal contract, grant or any other award covered by 31
U.S.C. 1352. Each tier must also disclose any lobbying with
non-Federal funds that takes place in connection with obtaining
any Federal award. Such disclosures are forwarded from tier to
tier up to the non-Federal award.
(J) See §200.322 Procurement of recovered materials.
The following table identifies each required contract provision and when each must be applied.
CONTRACT PROVISIONS MATRIX
Provision Contract Amount Notes

Threshold
A. Breach of Contract Simplified Acquisition Must identify sanctions and penalties

Threshold
B. Termination for Cause and $10,000 Must include basis of settlement and effects of
Convenience termination
C. Equal Employment All Construction References 41 CFR Part 60-1.3

Opportunity Contracts
D. Davis-Bacon Act $2,000 (Construction Must include Copeland "Anti-Kickback" Act

Contracts when
required by law)

Threshold
E. Contract Work Hours and $100,000 (Contacts Does not apply to the purchases of supplies or
Safety Standards Act Involving Mechanics or materials ordinarily available on the open market
Laborers)
F. Rights to Inventions Made All For research and development contracts

Under Contract or Agreement
G. Clean Air Act and Federal Simplified Acquisition Should include statement that violations will be
Water Pollution Control Act Threshold reported to federal awarding agency and the
Regional Office of the Environmental Protection
Agency (EPA).
H. Debarment and All Must ensure that no contracts are awarded to

Suspension parties listed on the Exclusions Extract on
SAM.gov.
I. Byrd Anti-Lobbying $100,000 Contracts must file a certification

Amendment
J. Procurement of Recovered $10,000 Applicable for state and local governments. See
Materials §200.322.
LESSON 4
MODULE CAPSTONE: REVISING
PROCUREMENT POLICIES
Capstone Objective
6.4.1 Practice assessing procurement policies for compliance with procurement requirements
4.1 MODULE CAPSTONE: REVISING PROCUREMENT POLICIES

Directions
Review the procurement policy found in the resource, Sample Non-federal Entity Policies, and
compare the sample procurement policy to the requirements found in 2 CFR 200.318 to 200.326.
Determine how the sample procurement policy must be revised to be in compliance with 2 CFR
200.
Notes on what 2 CFR 200 says about: How the policy should be revised:
Overview
Code of Conduct
Procurement Policies
LESSON 4 | MODULE CAPSTONE: REVISING PROCUREMENT POLICIES
Notes on what 2 CFR 200 says about: How the policy should be revised:
Competition
Cost and Price Analysis
Procurement Records
Contract Provisions
Contractor Selection Form
Action Planning
module.
Performance and Financial
Monitoring and Reporting
(2 CFR 200, Subpart D -
Subtitle IV)
MODULE 7 | PERFORMANCE AND FINANCIAL MONITORING AND REPORTING (2 CFR 200, SUBPART
D - SUBTITLE IV)
PERFORMANCE AND FINANCIAL

MONITORING AND REPORTING (2
CFR 200, SUBPART D - SUBTITLE IV)
Module Objective
 Use 2 CFR 200, Subpart D, to locate needed information about reporting requirements
The performance and financial monitoring and reporting requirements under 2 CFR 200 uses
language from OMB Circular A-102. The Uniform Guidance does not implement new requirement
changes for this subtitle. Non-federal entities that previously complied with 2 CFR 215 (A-110) will
find the language to be more concise.
Financial, Performance, and Real Property Reporting
MODULE 7 | PERFORMANCE AND FINANCIAL MONITORING AND REPORTING (2 CFR 200, SUBPART D - SUBTITLE IV)
SUBPART D - POST FEDERAL AWARD REQUIREMENTS - PERFORMANCE AND FINANCIAL MONITORING AND REPORTING
Section Source New Provisions

Language
§200.327 Financial reporting A-102
§200.328 Monitoring and reporting program A-102

performance
§200.329 Reporting on real property SF-429
D - SUBTITLE IV)
Lessons
1. Financial Reporting
2. Program Performance Reporting
3. Real Property Reporting
D - SUBTITLE IV)
D - SUBTITLE IV)
LESSON 1
FINANCIAL REPORTING
Lesson Objective
After completing this lesson, you should be able to:
7.1.1 Identify the requirements for financial reporting
1.1 §200.327 FINANCIAL REPORTING
Financial Reporting
LESSON 1 | FINANCIAL REPORTING
§200.327 Financial reporting.
Unless otherwise approved by OMB, the Federal awarding

agency may solicit only the standard, OMB-approved
governmentwide data elements for collection of financial
information (at time of publication the Federal Financial Report
or such future collections as may be approved by OMB and
listed on the OMB Web site). This information must be collected
with the frequency required by the terms and conditions of the
Federal award, but no less frequently than annually nor more
frequently than quarterly except in unusual circumstances, for
example where more frequent reporting is necessary for the
effective monitoring of the Federal award or could significantly
affect program outcomes, and preferably in coordination with
performance reporting.
Discussion
As noted, financial information must be collected with the

frequency required by the terms and conditions of the federal
award, but no less frequently than annually nor more frequently
than quarterly except in unusual circumstances.
 Poll: Have you encountered projects with grant awards

where more frequent reporting was deemed necessary?
A Yes
B No
 If so, what were the reasons for the increased reporting?
D - SUBTITLE IV)
LESSON 2
PROGRAM PERFORMANCE REPORTING
Lesson Objective
7.2.1 Identify the requirements for performance reporting
2.1 §200.328 MONITORING AND REPORTING PROGRAM

PERFORMANCE
Performance Reporting
LESSON 2 | PROGRAM PERFORMANCE REPORTING
200.328 Monitoring and reporting program performance.
(a) Monitoring by the non-Federal entity. The non-Federal entity

is responsible for oversight of the operations of the Federal
award supported activities. The non-Federal entity must monitor
its activities under Federal awards to assure compliance with
applicable Federal requirements and performance expectations
are being achieved. Monitoring by the non-Federal entity must
cover each program, function or activity. See also §200.331
Requirements for pass-through entities.
(b) Non-construction performance reports. The Federal

awarding agency must use standard, OMB-approved data
elements for collection of performance information (including
performance progress reports, Research Performance Progress
Report, or such future collections as may be approved by OMB
and listed on the OMB Web site).
(1) The non-Federal entity must submit performance reports at

the interval required by the Federal awarding agency or pass-
through entity to best inform improvements in program
outcomes and productivity. Intervals must be no less frequent
than annually nor more frequent than quarterly except in
unusual circumstances, for example where more frequent
reporting is necessary for the effective monitoring of the Federal
award or could significantly affect program outcomes. Annual
reports must be due 90 calendar days after the reporting period;
quarterly or semiannual reports must be due 30 calendar days
after the reporting period. Alternatively, the Federal awarding
agency or pass-through entity may require annual reports
before the anniversary dates of multiple year Federal awards.
The final performance report will be due 90 calendar days after
the period of performance end date. If a justified request is
submitted by a non-Federal entity, the Federal agency may
extend the due date for any performance report.
(2) The non-Federal entity must submit performance reports

using OMB-approved governmentwide standard information
collections when providing performance information. As
appropriate in accordance with above mentioned information
collections, these reports will contain, for each Federal award,
brief information on the following unless other collections are
approved by OMB:
(i) A comparison of actual accomplishments to the objectives of

the Federal award established for the period. Where the
accomplishments of the Federal award can be quantified, a
computation of the cost (for example, related to units of
accomplishment) may be required if that information will be
useful. Where performance trend data and analysis would be
informative to the Federal awarding agency program, the
Federal awarding agency should include this as a performance
reporting requirement.
D - SUBTITLE IV)
(ii) The reasons why established goals were not met, if

appropriate.
(iii) Additional pertinent information including, when appropriate,

analysis and explanation of cost overruns or high unit costs.
(c) Construction performance reports. For the most part, onsite

technical inspections and certified percentage of completion
data are relied on heavily by Federal awarding agencies and
pass-through entities to monitor progress under Federal awards
and subawards for construction. The Federal awarding agency
may require additional performance reports only when
considered necessary.
(d) Significant developments. Events may occur between the

scheduled performance reporting dates that have significant
impact upon the supported activity. In such cases, the non-
Federal entity must inform the Federal awarding agency or
pass-through entity as soon as the following types of conditions
become known:
(1) Problems, delays, or adverse conditions which will materially

impair the ability to meet the objective of the Federal award.
This disclosure must include a statement of the action taken, or
contemplated, and any assistance needed to resolve the
situation.
(2) Favorable developments which enable meeting time

schedules and objectives sooner or at less cost than anticipated
or producing more or different beneficial results than originally
planned.
(e) The Federal awarding agency may make site visits as

warranted by program needs.
(f) The Federal awarding agency may waive any performance

report required by this part if not needed.
Discussion
How has the increased emphasis on performance measurement

and reporting on outcomes affected your entity?
LESSON 2 | PROGRAM PERFORMANCE REPORTING
D - SUBTITLE IV)
LESSON 3
REAL PROPERTY REPORTING
Lesson Objective
7.3.1 Discuss the provisions regarding real property reporting
3.1 §200.329 REPORTING ON REAL PROPERTY
Real Property Reporting
LESSON 3 | REAL PROPERTY REPORTING
§200.329 Reporting on real property.
The Federal awarding agency or pass-through entity must

require a non-Federal entity to submit reports at least annually
on the status of real property in which the Federal government
retains an interest, unless the Federal interest in the real
property extends 15 years or longer. In those instances where
the Federal interest attached is for a period of 15 years or more,
the Federal awarding agency or pass-through entity, at its
option, may require the non-Federal entity to report at various
multi-year frequencies (e.g., every two years or every three
years, not to exceed a five-year reporting period; or a Federal
awarding agency or pass-through entity may require annual
reporting for the first three years of a Federal award and
thereafter require reporting every five years).
Discussion
Poll: How many of you have personally handled or were

involved in situations when the non-federal entity used, acquired,
or improved (under a federal award) real property where the
Federal government retained an interest in that property for a
period of 15 years or longer?
Note that this would require more frequent reporting than simply
annual reporting.
Action Planning
module.
Subrecipient Monitoring
and Management (2 CFR
200, Subpart D - Subtitle V)
MODULE 8 | SUBRECIPIENT MONITORING AND MANAGEMENT (2 CFR 200, SUBPART D - SUBTITLE
V)
SUBRECIPIENT MONITORING AND

MANAGEMENT (2 CFR 200, SUBPART
D - SUBTITLE V)
Module Objective
 Use 2 CFR 200, Subpart D, to locate needed information about subawards
The Uniform Guidance provides greater clarity to the role and expectations for pass-through entities
in awarding and monitoring subawards. This is the first time grants guidance has specifically
focused on subrecipient monitoring and management. In addition, 2 CFR 200 enables pass-through
entities, with prior approval, to make fixed amount subawards.
MODULE 8 | SUBRECIPIENT MONITORING AND MANAGEMENT (2 CFR 200, SUBPART D - SUBTITLE V)
SUBPART D - POST FEDERAL AWARD REQUIREMENTS - SUBRECIPIENT MONITORING AND MANAGEMENT
§200.330 Subrecipient and contractor A-133 Removes the term "vendor" and only uses the term "contractor."
determinations
§200.331 Requirements for pass- A-133 Identifies and explains the specific responsibilities of pass-through entities.
through entities
§200.332 Fixed amount subawards NEW Allows pass-through entities, with prior approval, to make fixed amount
subawards.
V)
Lessons
1. Subrecipient and Contractor Determinations
2. Requirements for Pass-Through Entities
V)
V)
LESSON 1
SUBRECIPIENT AND CONTRACTOR
DETERMINATIONS
Lesson Objective
8.1.1 Differentiate between the terms "subrecipient" and "contractor"
1.1 §200.330 SUBRECIPIENT AND CONTRACTOR DETERMINATIONS

The following table identifies the characteristics of subrecipients and contractors, as explained at 2
CFR 200.330(b) and (c).
Subrecipient Versus Contractors
The Uniform Guidance provides greater clarity to the role and expectations for passthrough entities
conducting oversight of subrecipients. The Uniform Guidance expands on the responsibilities of
LESSON 1 | SUBRECIPIENT AND CONTRACTOR DETERMINATIONS
pass-through entities found in previous guidance by providing for a more robust system of oversight
and monitoring. This subtitle uses language from Circular A-133, Audits of States, Local
Governments, and Nonprofits.
V)
§200.330 Subrecipient and contractor determinations.
The non-Federal entity may concurrently receive Federal

awards as a recipient, a subrecipient, and a contractor,
depending on the substance of its agreements with Federal
awarding agencies and pass-through entities. Therefore, a
pass-through entity must make case-by-case determinations
whether each agreement it makes for the disbursement of
Federal program funds casts the party receiving the funds in the
role of a subrecipient or a contractor. The Federal awarding
agency may supply and require recipients to comply with
additional guidance to support these determinations provided
such guidance does not conflict with this section.
(a) Subrecipients. A subaward is for the purpose of carrying out

a portion of a Federal award and creates a Federal assistance
relationship with the subrecipient. See §200.92 Subaward.
Characteristics which support the classification of the
nonFederal entity as a subrecipient include when the non-
Federal entity:
(1) Determines who is eligible to receive what Federal

assistance;
(2) Has its performance measured in relation to whether

objectives of a Federal program were met;
(3) Has responsibility for programmatic decision making;
(4) Is responsible for adherence to applicable Federal program

requirements specified in the Federal award; and
(5) In accordance with its agreement, uses the Federal funds to

carry out a program for a public purpose specified in authorizing
statute, as opposed to providing goods or services for the
benefit of the pass-through entity.
(b) Contractors. A contract is for the purpose of obtaining goods

and services for the non-Federal entity's own use and creates a
procurement relationship with the contractor. See §200.22
Contract. Characteristics indicative of a procurement
relationship between the non-Federal entity and a contractor are
when the contractor:
(1) Provides the goods and services within normal business

operations;
(2) Provides similar goods or services to many different

purchasers;
(3) Normally operates in a competitive environment;
LESSON 1 | SUBRECIPIENT AND CONTRACTOR DETERMINATIONS
(4) Provides goods or services that are ancillary to the operation

of the Federal program; and
(5) Is not subject to compliance requirements of the Federal

program as a result of the agreement, though similar
requirements may apply for other reasons.
(c) Use of judgment in making determination. In determining

whether an agreement between a pass-through entity and
another non-Federal entity casts the latter as a subrecipient or a
contractor, the substance of the relationship is more important
than the form of the agreement. All of the characteristics listed
above may not be present in all cases, and the pass-through
entity must use judgment in classifying each agreement as a
subaward or a procurement contract.
2 CFR 200.330 provides explanations for the terms "subrecipient" and "contractors" to better assist
pass-through entities in determining the most appropriate instrument. In previous guidance, the
words "contractor" and "vendor" were used interchangeably, which caused confusion among non-
federal entities. The Uniform Guidance does not use the term "vendor." The purpose of this section
is to provide clarity and consistency by establishing guidelines on how federal funds should be
treated.
It is important for non-federal entities to recognize that requirements affecting subawards and
contracts differ. The Uniform Guidance does not require non-federal entities to adopt or use new
terminology; however, recipients must comply with the appropriate regulations. It is the substance,
not the terminology, of the award that matters.
Discussion
 What challenges have you faced when making the distinction

between a subrecipient and a contractor?
V)
LESSON 2
REQUIREMENTS FOR PASS-THROUGH
ENTITIES
Lesson Objective
8.2.1 Identify the requirements for pass-through entities
2.1 §200.331 REQUIREMENTS FOR PASS-THROUGH ENTITIES
Requirements for Pass-Through Entities
§200.331 Requirements for pass-through entities.
All pass-through entities must:
(a) Ensure that every subaward is clearly identified to the

subrecipient as a subaward and includes the following
information at the time of the subaward and if any of these data
elements change, include the changes in subsequent subaward
modification. When some of this information is not available, the
pass-through entity must provide the best information available
to describe the Federal award and subaward. Required
information includes:
(1) Federal Award Identification.
(i) Subrecipient name (which must match the name associated

with its unique entity identifier);
(ii) Subrecipient's unique entity identifier;
(iii) Federal Award Identification Number (FAIN);
LESSON 2 | REQUIREMENTS FOR PASS-THROUGH ENTITIES
(iv) Federal Award Date (see §200.39 Federal award date) of

award to the recipient by the Federal agency;
(v) Subaward Period of Performance Start and End Date;
(vi) Amount of Federal Funds Obligated by this action by the

pass-through entity to the subrecipient;
(vii) Total Amount of Federal Funds Obligated to the

subrecipient;
(viii) Total Amount of the Federal Award committed to the

subrecipient by the pass-through entity;
(ix) Federal award project description, as required to be

responsive to the Federal Funding Accountability and
Transparency Act (FFATA);
(x) Name of Federal awarding agency, pass-through entity, and

contact information for awarding official of the Pass-through
entity,
(xi) Assistance Listings (formerly known as CFDA) Number and

Name; the pass-through entity must identify the dollar amount
made available under each Federal award and the CFDA
number at time of disbursement;
(xii) Identification of whether the award is R&D; and
(xiii) Indirect cost rate for the Federal award (including if the de
minimis rate is charged per §200.414 Indirect (F&A) costs).
(2) All requirements imposed by the pass-through entity on the

subrecipient so that the Federal award is used in accordance
with Federal statutes, regulations and the terms and conditions
of the Federal award;
(3) Any additional requirements that the pass-through entity

imposes on the subrecipient in order for the pass-through entity
to meet its own responsibility to the Federal awarding agency
including identification of any required financial and
performance reports;
(4) An approved federally recognized indirect cost rate

negotiated between the subrecipient and the Federal
Government or, if no such rate exists, either a rate negotiated
between the pass-through entity and the subrecipient (in
compliance with this part), or a de minimis indirect cost rate as
defined in §200.414 Indirect (F&A) costs, paragraph (f);
(5) A requirement that the subrecipient permit the pass-through

entity and auditors to have access to the subrecipient's records
and financial statements as necessary for the pass-through
V)
entity to meet the requirements of this part; and
(6) Appropriate terms and conditions concerning closeout of the

subaward.
(b) Evaluate each subrecipient's risk of noncompliance with

Federal statutes, regulations, and the terms and conditions of
the subaward for purposes of determining the appropriate
subrecipient monitoring described in paragraphs (d) and (e) of
this section, which may include consideration of such factors as:
(1) The subrecipient's prior experience with the same or similar

subawards;
(2) The results of previous audits including whether or not the

subrecipient receives a Single Audit in accordance with Subpart
F—Audit Requirements of this part, and the extent to which the
same or similar subaward has been audited as a major
program;
(3) Whether the subrecipient has new personnel or new or

substantially changed systems; and
(4) The extent and results of Federal awarding agency

monitoring (e.g., if the subrecipient also receives Federal
awards directly from a Federal awarding agency).
(c) Consider imposing specific subaward conditions upon a

subrecipient if appropriate as described in §200.207 Specific
conditions.
(d) Monitor the activities of the subrecipient as necessary to

ensure that the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms
and conditions of the subaward; and that subaward
performance goals are achieved. Pass-through entity monitoring
of the subrecipient must include:
(1) Reviewing financial and performance reports required by the

pass-through entity.
(2) Following-up and ensuring that the subrecipient takes timely

and appropriate action on all deficiencies pertaining to the
Federal award provided to the subrecipient from the pass-
through entity detected through audits, on-site reviews, and
other means.
(3) Issuing a management decision for audit findings pertaining

to the Federal award provided to the subrecipient from the pass-
through entity as required by §200.521 Management decision.
(e) Depending upon the pass-through entity's assessment of
LESSON 2 | REQUIREMENTS FOR PASS-THROUGH ENTITIES
risk posed by the subrecipient (as described in paragraph (b) of

this section), the following monitoring tools may be useful for the
pass-through entity to ensure proper accountability and
compliance with program requirements and achievement of
performance goals:
(1) Providing subrecipients with training and technical

assistance on program-related matters; and
(2) Performing on-site reviews of the subrecipient's program

operations;
(3) Arranging for agreed-upon-procedures engagements as

described in §200.425 Audit services.
(f) Verify that every subrecipient is audited as required by

Subpart F—Audit Requirements of this part when it is expected
that the subrecipient's Federal awards expended during the
respective fiscal year equaled or exceeded the threshold set
forth in §200.501 Audit requirements.
(g) Consider whether the results of the subrecipient's audits, on-

site reviews, or other monitoring indicate conditions that
necessitate adjustments to the pass-through entity's own
records.
(h) Consider taking enforcement action against noncompliant

subrecipients as described in §200.338 Remedies for
noncompliance of this part and in program regulations.
The Uniform Guidance lists eight responsibilities of pass-through entities. Many of the
responsibilities were previously included in A-133; however, the Uniform Guidance has expanded
upon some of the requirements. For example, pass-through entities must conduct a risk
assessment by evaluating the ability of the subrecipient to comply with federal statutes, regulations,
and the terms and conditions of the subaward. It is important to note that under 2 CFR 200, the
pass-through entity does not have to conduct the risk assessment before making an award; 2 CFR
200 only requires that the risk assessment is conducted at some point determined by the pass-
through entity.
Pass-through entities should pay particular attention to 2 CFR 200.331(a)(4). This section explains
the process for establishing an indirect (F&A) cost rate for subrecipients. Pass-through entities may:
 Accept the negotiated indirect (F&A) cost rate agreed upon by the cognizant agency for indirect
costs
 Provide the subrecipient with the 10% de minimis indirect cost rate, if the subrecipient has
elected this option
 If no rate exists, negotiate an indirect (F&A) cost rate with the subrecipient
The following figure provides a graphic illustration of the indirect cost rate options for pass-through
entities.
V)
IDC Decision Tree for Pass-Through Entities
Discussion
 Of the various pass-through entity requirements regarding

federal awards and sub-awards, what would you consider to
be the most important and why?
 In your own experience, which pass-through entity
requirement have you found to be the biggest challenge for
entities?
2.2 §200.332 FIXED AMOUNT SUBAWARDS

§200.332 Fixed amount subawards.
With prior written approval from the Federal awarding agency, a

pass-through entity may provide subawards based on fixed
amounts up to the Simplified Acquisition Threshold, provided
that the subawards meet the requirements for fixed amount
awards in §200.201 Use of grant agreements (including fixed
amount awards), cooperative agreements, and contracts.
V)
Action Planning
module.
Record Retention and
Access
MODULE 9 | RECORD RETENTION AND ACCESS
RECORD RETENTION AND ACCESS

Module Objective
 Use 2 CFR 200, Subpart D, to locate information about award records
2 CFR 200 slightly modifies the record retention and access requirements. Perhaps the most
significant change in this subtitle is the recommendation that federal awarding agencies and pass-
through entities use open and machine readable formats. The language for this subtitle is from A-
102.
SUBPART D - POST FEDERAL AWARD REQUIREMENTS - RECORD RETENTION AND ACCESS
§200.333 Retention requirements for A-102 The record retention period is clarified as three years from the submission date of
records the final financial report.
§200.334 Requests for transfer of A-102

records
§200.335 Methods for collection, A-102 Federal awarding agencies and non-federal entities are encouraged to use open
transmission and storage of information and machine readable formats for all documents.
§200.336 Access to records A-102 Access to records revealing the name of a crime victim is limited.
§200.337 Restrictions on public access A-102

to records
Lessons
1. Retention Requirements for Records
2. Transfer and Storage Requirements for Records
LESSON 1
RETENTION REQUIREMENTS FOR
RECORDS
Lesson Objective
9.1.1 Discuss the record retention requirements
1.1 §200.333 RETENTION REQUIREMENTS FOR RECORDS
Record Retention Requirements
LESSON 1 | RETENTION REQUIREMENTS FOR RECORDS
§200.333 Retention requirements for records.
Financial records, supporting documents, statistical records,

and all other non-Federal entity records pertinent to a Federal
award must be retained for a period of three years from the date
of submission of the final expenditure report or, for Federal
awards that are renewed quarterly or annually, from the date of
the submission of the quarterly or annual financial report,
respectively, as reported to the Federal awarding agency or
pass-through entity in the case of a subrecipient. Federal
awarding agencies and pass-through entities must not impose
any other record retention requirements upon non-Federal
entities. The only exceptions are the following:
(a) If any litigation, claim, or audit is started before the expiration

of the 3-year period, the records must be retained until all
litigation, claims, or audit findings involving the records have
been resolved and final action taken.
(b) When the non-Federal entity is notified in writing by the

Federal awarding agency, cognizant agency for audit, oversight
agency for audit, cognizant agency for indirect costs, or pass-
through entity to extend the retention period.
(c) Records for real property and equipment acquired with

Federal funds must be retained for 3 years after final
disposition.
(d) When records are transferred to or maintained by the

Federal awarding agency or pass-through entity, the 3-year
retention requirement is not applicable to the non-Federal entity.
(e) Records for program income transactions after the period of

performance. In some cases recipients must report program
income after the period of performance. Where there is such a
requirement, the retention period for the records pertaining to
the earning of the program income starts from the end of the
non-Federal entity's fiscal year in which the program income is
earned.
(f) Indirect cost rate proposals and cost allocations plans. This
paragraph applies to the following types of documents and their
supporting records: indirect cost rate computations or proposals,
cost allocation plans, and any similar accounting computations
of the rate at which a particular group of costs is chargeable
(such as computer usage chargeback rates or composite fringe
benefit rates).
(1) If submitted for negotiation. If the proposal, plan, or other

computation is required to be submitted to the Federal
government (or to the pass-through entity) to form the basis for
negotiation of the rate, then the 3-year retention period for its
supporting records starts from the date of such submission.
(2) If not submitted for negotiation. If the proposal, plan, or

other computation is not required to be submitted to the Federal
government (or to the pass-through entity) for negotiation
purposes, then the 3-year retention period for the proposal,
plan, or computation and its supporting records starts from the
end of the fiscal year (or other accounting period) covered by
the proposal, plan, or other computation.
The Uniform Guidance explicitly states that non-federal entities must retain all grants-related
records and documents for three years from the submission date of the final financial report. It is
important to note that the provision states "date of submission" and does not refer to the date of
receipt by the federal awarding agency or pass-through entity. This provision also indicates when
the three-year record retention requirement may be waived.
LESSON 1 | RETENTION REQUIREMENTS FOR RECORDS
Discussion
§200.333 Retention Requirements for Records addresses

several exceptions that would lengthen the standard three-year
time period required for records retention by the non-federal
entity. What are some of these exceptions?
LESSON 2
TRANSFER AND STORAGE
REQUIREMENTS FOR RECORDS
Lesson Objective
9.2.1 Explain the provisions regarding transferring, collecting, storing, and transmitting records.
2.1 §200.334 REQUESTS FOR TRANSFERS OF RECORDS

§200.334 Requests for transfer of records.
The Federal awarding agency must request transfer of certain

records to its custody from the non-Federal entity when it
determines that the records possess long-term retention value.
However, in order to avoid duplicate recordkeeping, the Federal
awarding agency may make arrangements for the non-Federal
entity to retain any records that are continuously needed for joint
use.
Discussion
 When would the federal awarding agency request transfer of

certain records to its custody from the non-federal entity?
LESSON 2 | TRANSFER AND STORAGE REQUIREMENTS FOR RECORDS
2.2 §200.335 METHODS FOR COLLECTION, TRANSMISSION AND

STORAGE OF INFORMATION
§200.335 Methods for collection, transmission and storage
of information.
In accordance with the May 2013 Executive Order on Making

Open and Machine Readable the New Default for Government
Information, the Federal awarding agency and the non-Federal
entity should, whenever practicable, collect, transmit, and store
Federal award-related information in open and machine
readable formats rather than in closed formats or on paper. The
Federal awarding agency or pass-through entity must always
provide or accept paper versions of Federal award-related
information to and from the non-Federal entity upon request. If
paper copies are submitted, the Federal awarding agency or
pass-through entity must not require more than an original and
two copies. When original records are electronic and cannot be
altered, there is no need to create and retain paper copies.
When original records are paper, electronic versions may be
substituted through the use of duplication or other forms of
electronic media provided that they are subject to periodic
quality control reviews, provide reasonable safeguards against
alteration, and remain readable.
The Uniform Guidance requires federal awarding agencies and non-federal entities, whenever
practical, to collect, transmit, and store award-related information in open and machine readable
formats. Federal awarding agencies and pass-through entities are required, however, to accept
paper copies of award-related documents. Federal awarding agencies and non-federal entities must
have internal controls in place to protect and safeguard records from being altered, damaged,
deleted, or destroyed. Additional precautions should be taken to protect personally identifiable
information (PII).
Refer to Website
Data.gov provides a primer on machine readable formats. This

primer can be found at:
https://www.data.gov/developers/blog/primer-machine-
readability-online-documents-and-data
2 CFR 200.335 is designed to comply with Executive Order 13642. OMB issued Memorandum M-
13-13 to provide guidance to federal agencies in implementing the Executive Order.
Refer to Website

http://www.whitehouse.gov/sites/default/files/omb/memoranda/2013/m-
13-13.pdf
2.3 §200.336 ACCESS TO RECORDS

§200.336 Access to records.
(a) Records of non-Federal entities. The Federal awarding

agency, Inspectors General, the Comptroller General of the
United States, and the pass-through entity, or any of their
authorized representatives, must have the right of access to any
documents, papers, or other records of the non-Federal entity
which are pertinent to the Federal award, in order to make
audits, examinations, excerpts, and transcripts. The right also
includes timely and reasonable access to the non-Federal
entity's personnel for the purpose of interview and discussion
related to such documents.
(b) Only under extraordinary and rare circumstances would such

access include review of the true name of victims of a crime.
Routine monitoring cannot be considered extraordinary and rare
circumstances that would necessitate access to this information.
When access to the true name of victims of a crime is
necessary, appropriate steps to protect this sensitive
information must be taken by both the non-Federal entity and
the Federal awarding agency. Any such access, other than
under a court order or subpoena pursuant to a bona fide
confidential investigation, must be approved by the head of the
Federal awarding agency or delegate.
(c) Expiration of right of access. The rights of access in this

section are not limited to the required retention period but last
as long as the records are retained. Federal awarding agencies
and pass-through entities must not impose any other access
requirements upon non-Federal entities.
LESSON 2 | TRANSFER AND STORAGE REQUIREMENTS FOR RECORDS
2.4 §200.337 RESTRICTIONS ON PUBLIC ACCESS TO RECORDS

§200.337 Restrictions on public access to records.
No Federal awarding agency may place restrictions on the non-

Federal entity that limit public access to the records of the non-
Federal entity pertinent to a Federal award, except for protected
personally identifiable information (PII) or when the Federal
awarding agency can demonstrate that such records will be kept
confidential and would have been exempted from disclosure
pursuant to the Freedom of Information Act (5 U.S.C. 552) or
controlled unclassified information pursuant to Executive Order
13556 if the records had belonged to the Federal awarding
agency. The Freedom of Information Act (5 U.S.C. 552) (FOIA)
does not apply to those records that remain under a non-
Federal entity's control except as required under §200.315
Intangible property. Unless required by Federal, state, local, and
tribal statute, non-Federal entities are not required to permit
public access to their records. The non-Federal entity's records
provided to a Federal agency generally will be subject to FOIA
and applicable exemptions.
2 CFR 200.337 explains the extent to which the public may request and access grants-related
documents. It is important to note that the Freedom of Information Act (FOIA) does not apply to
records that remain under a non-federal entity's control. Grants-related records held by a federal
awarding agency are, however, subject to FOIA requests.
Action Planning
module.
Remedies for
Noncompliance (2 CFR 200,
Subpart D - Subtitle VII)
MODULE 10 | REMEDIES FOR NONCOMPLIANCE (2 CFR 200, SUBPART D - SUBTITLE VII)
REMEDIES FOR NONCOMPLIANCE (2

CFR 200, SUBPART D - SUBTITLE VII)
Module Objective
 Use 2 CFR 200, Subpart D, to locate needed information about noncompliance and
termination
One of the objectives OMB and the COFAR had in developing 2 CFR 200 was to strengthen the
oversight of federal funds and to reduce the risk of waste, fraud, and abuse. This subtitle seeks to
meet that objective by providing greater detail to assist federal awarding agencies and pass-through
entities in remedying recipient noncompliance.
SUBPART D - POST FEDERAL AWARD REQUIREMENTS - REMEDIES FOR NONCOMPLIANCE
§200.338 Remedies for noncompliance 2 CFR 215 A list of remedies for noncompliance is provided.
§200.339 Termination 2 CFR 215
§200.340 Notification of termination 2 CFR 215 Requires federal awarding agencies and pass-through entities to notify a non-
requirement federal entity when an award is terminated.
§200.341 Opportunities to object, 2 CFR 215

hearings and appeals
§200.342 Effects of suspension and 2 CFR 215

termination
Informal and Formal Corrective Actions for Insufficient Performance
Lessons
1. Termination Process
2. Module Capstone: Using the Administrative Requirements to Resolve Termination and

Enforcement Issues
LESSON 1
TERMINATION PROCESS
Lesson Objective
10.1.1 Explain the process to terminate a federal award
Award Termination Conditions; Agency FAPIIS Requirements; and Agency, Non-Federal Entity, and Pass-Though Entity Responsibilities
Concerning Closeout
LESSON 1 | TERMINATION PROCESS
1.1 §200.339 TERMINATION

§200.339 Termination.
(a) The Federal award may be terminated in whole or in part as

follows:
(1) By the Federal awarding agency or pass-through entity, if a

non-Federal entity fails to comply with the terms and conditions
of a Federal award;
(2) By the Federal awarding agency or pass-through entity for

cause;
(3) By the Federal awarding agency or pass-through entity with

the consent of the non-Federal entity, in which case the two
parties must agree upon the termination conditions, including
the effective date and, in the case of partial termination, the
portion to be terminated; or
(4) By the non-Federal entity upon sending to the Federal

awarding agency or pass-through entity written notification
setting forth the reasons for such termination, the effective date,
and, in the case of partial termination, the portion to be
terminated. However, if the Federal awarding agency or pass-
through entity determines in the case of partial termination that
the reduced or modified portion of the Federal award or
subaward will not accomplish the purposes for which the
Federal award was made, the Federal awarding agency or
pass-through entity may terminate the Federal award in its
entirety.
(b) When a Federal awarding agency terminates a Federal

award prior to the end of the period of performance due to the
non-Federal entity's material failure to comply with the Federal
award terms and conditions, the Federal awarding agency must
report the termination to the OMB-designated integrity and
performance system accessible through SAM (currently
FAPIIS).
(1) The information required under paragraph (b) of this section

is not to be reported to designated integrity and performance
system until the non-Federal entity either—
(i) Has exhausted its opportunities to object or challenge the

decision, see §200.341 Opportunities to object, hearings and
appeals; or
(ii) Has not, within 30 calendar days after being notified of the
termination, informed the Federal awarding agency that it
intends to appeal the Federal awarding agency's decision to
terminate.
(2) If a Federal awarding agency, after entering information into
the designated integrity and performance system about a

termination, subsequently:
(i) Learns that any of that information is erroneous, the Federal

awarding agency must correct the information in the system
within three business days;
(ii) Obtains an update to that information that could be helpful to

other Federal awarding agencies, the Federal awarding agency
is strongly encouraged to amend the information in the system
to incorporate the update in a timely way.
(3) Federal awarding agencies, shall not post any information

that will be made publicly available in the non-public segment of
designated integrity and performance system that is covered by
a disclosure exemption under the Freedom of Information Act. If
the non-Federal entity asserts within seven calendar days to the
Federal awarding agency who posted the information, that some
of the information made publicly available is covered by a
disclosure exemption under the Freedom of Information Act, the
Federal awarding agency who posted the information must
remove the posting within seven calendar days of receiving the
assertion. Prior to reposting the releasable information, the
Federal agency must resolve the issue in accordance with the
agency's Freedom of Information Act procedures.
(c) When a Federal award is terminated or partially terminated,

both the Federal awarding agency or pass-through entity and
the non-Federal entity remain responsible for compliance with
the requirements in §§200.343 Closeout and 200.344 Post-
closeout adjustments and continuing responsibilities.
This section was significantly impacted on July 22, 2015 with the release of the Federal Awardee
Performance and Integrity System (FAPIIS) revisions to 2 CFR, adding the requirement for the
agency to report terminations for material failure to comply with award terms and conditions to
FAPIIS.
Example: State Department Terminates Award and Updates

FAPIIS
The State Department terminated a grant award for the

recipient’s failure to comply with reporting and performance
measurement requirements. The State Department reported the
termination to FAPIIS and included the letter of termination in
the file. The following is an excerpt from the termination letter:
“[We have] determined that all applicable term and conditions

pertaining to the grant award…has not been fulfilled as follows.
 Reporting:
— According to the award’s amended reporting schedule,
reports were submitted long after their scheduled filing
dates: the report due January 31, 2013 was received
August 1, 2013 (six months overdue); the report due
July 30, 2013 was received March 10, 2014 (eight
months overdue); and the report due on October 30,
2013 was received July 15, 2015 (one year and nine
months overdue).
 Outcomes: The amended Award Specifics identifies the
following performance measurements evidence of which
were to periodically reported in [progress] reports.
— Number of women owned businesses
established/expanded
— Evidence of new or expanded access to credit
attributable to the project
— Evidence of cross-border activity particularly to trade
According to the narrative reports, there was insufficient
evidence to demonstrate these project objectives were fully
accomplished. This finding was substantiated during our site
visit…”
Discussion
How might this termination letter in FAPIIS affect future award

decisions?
1.2 §200.340 NOTIFICATION OF TERMINATION REQUIREMENT

§200.340 Notification of termination requirement.
(a) The Federal agency or pass-through entity must provide to

the non-Federal entity a notice of termination.
(b) If the Federal award is terminated for the non-Federal

entity's material failure to comply with the Federal statutes,
regulations, or terms and conditions of the Federal award, the
notification must state that—
(1) The termination decision will be reported to the OMB-

through SAM (currently FAPIIS);
(2) The information will be available in the OMB-designated

integrity and performance system for a period of five years from
the date of the termination, then archived;
(3) Federal awarding agencies that consider making a Federal

award to the non-Federal entity during that five year period must
consider that information in judging whether the non-Federal
entity is qualified to receive the Federal award, when the
Federal share of the Federal award is expected to exceed the
simplified acquisition threshold over the period of performance;
(4) The non-Federal entity may comment on any information the

OMB-designated integrity and performance system contains
about the non-Federal entity for future consideration by Federal
awarding agencies. The non-Federal entity may submit
comments to the awardee integrity and performance portal
accessible through SAM (currently (CPARS).
(5) Federal awarding agencies will consider non-Federal entity

comments when determining whether the non-Federal entity is
qualified for a future Federal award.
(c) Upon termination of a Federal award, the Federal awarding

agency must provide the information required under FFATA to
the Federal Web site established to fulfill the requirements of
FFATA, and update or notify any other relevant governmentwide
systems or entities of any indications of poor performance as
required by 41 U.S.C. 417b and 31 U.S.C. 3321 and
implementing guidance at 2 CFR part 77 (forthcoming at time of
publication). See also the requirements for Suspension and
Debarment at 2 CFR part 180.
1.3 §200.341 OPPORTUNITIES TO OBJECT, HEARINGS, AND

APPEALS
§200.341 Opportunities to object, hearings and appeals.
Upon taking any remedy for non-compliance, the Federal

awarding agency must provide the non-Federal entity an
opportunity to object and provide information and
documentation challenging the suspension or termination
action, in accordance with written processes and procedures
published by the Federal awarding agency. The Federal
awarding agency or pass-through entity must comply with any
requirements for hearings, appeals or other administrative
proceedings to which the non-Federal entity is entitled under
any statute or regulation applicable to the action involved.
1.4 §200.342 EFFECTS OF SUSPENSION AND TERMINATION

§200.342 Effects of suspension and termination.
Costs to the non-Federal entity resulting from obligations

incurred by the non-Federal entity during a suspension or after
termination of a Federal award or subaward are not allowable
unless the Federal awarding agency or pass-through entity
expressly authorizes them in the notice of suspension or
termination or subsequently. However, costs during suspension
or after termination are allowable if:
(a) The costs result from obligations which were properly

incurred by the non-Federal entity before the effective date of
suspension or termination, are not in anticipation of it; and
(b) The costs would be allowable if the Federal award was not
suspended or expired normally at the end of the period of
performance in which the termination takes effect.
LESSON 2
MODULE CAPSTONE: USING THE
ADMINISTRATIVE REQUIREMENTS TO
RESOLVE TERMINATION AND
ENFORCEMENT ISSUES
Capstone Objective
10.2.1 Practice using 2 CFR 200, Subpart D, to locate needed information about noncompliance
and termination
LESSON 2 | MODULE CAPSTONE: USING THE ADMINISTRATIVE REQUIREMENTS TO RESOLVE
TERMINATION AND ENFORCEMENT ISSUES
2.1 MODULE CAPSTONE: USING THE ADMINISTRATIVE

REQUIREMENTS TO RESOLVE TERMINATION AND
ENFORCEMENT ISSUES
Overview
Work as a team to apply the termination provisions found in the Uniform Guidance.
Directions
1. Answer the following questions.
2. Include citations for your answers.
Questions
1. You are a federal grants official. You read an article in the newspaper that the executive
director of XYZ Nonprofit (one of your grant recipients) quit after a fight with XYZ's board of
directors and that several staff members and senior management personnel subsequently also
left. When you call XYZ, the receptionist tells you that none of the key project personnel still
work at XYZ and that the project has been put on hold indefinitely. What action should you
take?
2. What if, in the above situation, instead of reading about it in the newspaper, you received a
letter from XYZ's board of directors informing you that all key staff had left and requesting that
XYZ be let out of its grant agreement?
3. Big City is performing a $5 million construction project supported by your agency. The annual
audit reveals that the city failed to require its contractors to pay their employees Davis-Bacon
prevailing wage rates. What should your agency do to deal with this situation?
4. Because of procurement irregularities, the government of Smalltown has been placed on high-
risk status with special award conditions, including payment on a reimbursement basis.
Problems continue, however, and your agency suspends its award to Smalltown on March 1
pending termination proceedings. On March 15, you receive an SF-270, requesting
reimbursement. Should you deny or approve the payment request?
Action Planning
module.
Closeout Requirements (2
Subtitles VIII-X)
MODULE 11 | CLOSEOUT REQUIREMENTS (2 CFR 200, SUBPART D - SUBTITLES VIII-X)
CLOSEOUT REQUIREMENTS (2 CFR

200, SUBPART D - SUBTITLES VIII-X)
Module Objective
 Use 2 CFR 200, Subpart D, to locate needed information about closeout
2 CFR 200 retains the closeout and post-closeout procedures found in previous guidance. There
are, however, two significant new requirements in this subtitle:
 2 CFR 200.343 encourages federal awarding agencies and pass-through entities to close out
federal awards within one year of receipt and acceptance of the final reports
 2 CFR 200.344 requires federal awarding agencies and pass-through entities to make all cost
disallowances within the record retention period. Federal awarding agencies and pass-through
entities may, however, still recover funds at any time.
SUBPART D - POST FEDERAL AWARD REQUIREMENTS - CLOSEOUT REQUIREMENTS
§200.343 Closeout 2 CFR 215  Requires pass-through entities to provide specific information to
subrecipients for closeout procedures; and
 Encourages federal awarding agencies and pass-through entities to complete
all closeout actions within one year of receipt and acceptance of final reports.
§200.344 Post-closeout adjustments A-102 Federal awarding agencies and pass-through entities must make cost
and continuing responsibilities disallowances within the record retention period.
§200.345 Collection of amounts due A-102 Clarifies that non-federal entities have 90 days to remit payment on outstanding
debts.
Lessons
1. Closeout Process
2. Post-Closeout Requirements
LESSON 1
CLOSEOUT PROCESS
Lesson Objective
11.1.1 Explain the closeout process
LESSON 1 | CLOSEOUT PROCESS
1.1 §200.343 CLOSEOUT
Closeout Requirements
§200.343 Closeout.
The Federal awarding agency or pass-through entity will close-

out the Federal award when it determines that all applicable
administrative actions and all required work of the Federal
award have been completed by the non-Federal entity. This
section specifies the actions the non-Federal entity and Federal
awarding agency or pass-through entity must take to complete
this process at the end of the period of performance.
(a) The non-Federal entity must submit, no later than 90

calendar days after the end date of the period of performance,
all financial, performance, and other reports as required by the
terms and conditions of the Federal award. The Federal
awarding agency or pass-through entity may approve
extensions when requested by the non-Federal entity.
(b) Unless the Federal awarding agency or pass-through entity

authorizes an extension, a non-Federal entity must liquidate all
obligations incurred under the Federal award not later than 90
calendar days after the end date of the period of performance
as specified in the terms and conditions of the Federal award.
(c) The Federal awarding agency or pass-through entity must

make prompt payments to the non-Federal entity for allowable
reimbursable costs under the Federal award being closed out.
(d) The non-Federal entity must promptly refund any balances

of unobligated cash that the Federal awarding agency or pass-
through entity paid in advance or paid and that are not
authorized to be retained by the non-Federal entity for use in
other projects. See OMB Circular A-129 and see §200.345
Collection of amounts due, for requirements regarding
unreturned amounts that become delinquent debts.
(e) Consistent with the terms and conditions of the Federal

award, the Federal awarding agency or pass-through entity
must make a settlement for any upward or downward
adjustments to the Federal share of costs after closeout reports
are received.
(f) The non-Federal entity must account for any real and
personal property acquired with Federal funds or received from
the Federal Government in accordance with §§200.310
Insurance coverage through 200.316 Property trust relationship
and 200.329 Reporting on real property.
(g) The Federal awarding agency or pass-through entity should

complete all closeout actions for Federal awards no later than
one year after receipt and acceptance of all required final
reports.
2 CFR 200.343 identifies the closeout responsibilities and procedures for federal awarding agencies
and non-federal entities. The Uniform Guidance suggests closeout occurs within one year of
accepting the final reports, but does not require it. In recent years, there has been increasing
demands from Offices of Inspectors General, the Government Accountability Office, and Congress
for agencies to improve the timeliness of grant closeout. OMB included the one-year time provision
to address those concerns.
The following list identifies the responsibilities for federal agencies, pass-through entities, and non-
federal entities in the closeout process.
 Federal agency and pass-through entities:
— Must make prompt payments
— Must settle federal share of costs
— Should complete closeout within 1 year of receipt and acceptance of final reports
 Non-federal entities must:
— Submit all reports no later than 90 calendar days after end of grant
— Liquidate all obligations within 90 calendar days after end of grant
— Promptly refund any balances of unobligated cash
— Account for property
Discussion
What are the challenges to closing out a grant within one year of
accepting final reports?
LESSON 2
POST-CLOSEOUT REQUIREMENTS
Lesson Objective
11.2.1 Discuss the agency and recipient responsibilities after closeout
What Closing Out of a Federal Award Does Not Affect
LESSON 2 | POST-CLOSEOUT REQUIREMENTS
2.1 §200.344 POST-CLOSEOUT ADJUSTMENTS

§200.344 Post-closeout adjustments and continuing
responsibilities.
(a) The closeout of a Federal award does not affect any of the
following.
(1) The right of the Federal awarding agency or pass-through

entity to disallow costs and recover funds on the basis of a later
audit or other review. The Federal awarding agency or pass-
through entity must make any cost disallowance determination
and notify the non-Federal entity within the record retention
period.
(2) The obligation of the non-Federal entity to return any funds

due as a result of later refunds, corrections, or other
transactions including final indirect cost rate adjustments.
(3) Audit requirements in Subpart F—Audit Requirements of this

part.
(4) Property management and disposition requirements in

Subpart D—Post Federal Award Requirements of this part,
§§200.310 Insurance Coverage through 200.316 Property trust
relationship.
(5) Records retention as required in Subpart D—Post Federal

Award Requirements of this part, §§200.333 Retention
requirements for records through 200.337 Restrictions on public
access to records.
(b) After closeout of the Federal award, a relationship created

under the Federal award may be modified or ended in whole or
in part with the consent of the Federal awarding agency or pass-
through entity and the non-Federal entity, provided the
responsibilities of the non-Federal entity referred to in paragraph
(a) of this section including those for property management as
applicable, are considered and provisions made for continuing
responsibilities of the non-Federal entity, as appropriate.
This section prohibits federal awarding agencies and pass-through entities from disallowing costs
after the three-year retention period. This is a new provision found in the Uniform Guidance that
was not included in the previous uniform administrative requirements. It is important to note that
responsibilities relating to grant awards, especially pertaining to property management, does not
end after closeout.
Discussion
Poll: All of the following items are unaffected by the closeout of

grants except:
A The right of an agency to disallow costs.
B Audit requirements identified in Subpart F.
C Record retention requirements.
D The obligation of the recipient to return funds.
E Property management and disposition requirements.
F None of the above.
2.2 §200.345 COLLECTION OF AMOUNTS DUE

§200.345 Collection of amounts due.
(a) Any funds paid to the non-Federal entity in excess of the

amount to which the non-Federal entity is finally determined to
be entitled under the terms of the Federal award constitute a
debt to the Federal government. If not paid within 90 calendar
days after demand, the Federal awarding agency may reduce
the debt by:
(1) Making an administrative offset against other requests for

reimbursements;
(2) Withholding advance payments otherwise due to the non-

Federal entity; or
(3) Other action permitted by Federal statute.
(b) Except where otherwise provided by statutes or regulations,

the Federal awarding agency will charge interest on an overdue
debt in accordance with the Federal Claims Collection
Standards (31 CFR parts 900 through 999). The date from
which interest is computed is not extended by litigation or the
filing of any form of appeal.
Action Planning
module.
Course Capstone
MODULE 12 | COURSE CAPSTONE
COURSE CAPSTONE
Lessons
1. Course Capstone: Finding Answers in the Administrative Requirements
LESSON 1
COURSE CAPSTONE: FINDING
ANSWERS IN THE ADMINISTRATIVE
REQUIREMENTS
Capstone Objective
 Apply the administrative requirements found in the Uniform Guidance
LESSON 1 | COURSE CAPSTONE: FINDING ANSWERS IN THE ADMINISTRATIVE REQUIREMENTS
1.1 COURSE CAPSTONE: FINDING ANSWERS IN THE

Directions
Research each scenario assigned to your group, identify the proper citation, and be prepared to
present your answers.
Scenario 1
Facts: The Department of Labor (DOL) has identified the XYZ

Community Action Agency as having an accounting system that
is inadequate to identify, manage, and control its costs under
their DOL grant. As a result, DOL has established a special
award condition (or “high risk” determination) that the XYZ
Agency should hire a CPA firm to establish a more acceptable
accounting system. DOL has given XYZ three months to
accomplish this task.
1. Is it within DOL’s right to do this?
2. Does DOL have to get OMB approval to take this action?
3. Who pays the costs?
4. What happens if XYZ refuses to cooperate?
Scenario 2
Facts: The Department of Health and Human Services (HHS)

wants to require Head Start grantees to furnish reports showing
costs, on a per child basis, of providing health and nutritional
services to children receiving Head Start services.
5. Does the Uniform Guidance allow HHS to do this?
6. If so, who pays the costs of establishing such a system?
Scenario 3
Facts: The University of South Central North Dakota has a

grant, which requires cost sharing, from the National Science
Foundation (NSF). Dr. Jones is the university's principal
investigator on the grant. Rather than charging Dr. Jones’
salary to the grant as a direct charge, the university intends to
pay her salary from its own resources and show that payment
as part of its cost share.
7. May the university do this? Why or why not?
8. May the university include Dr. Jones’ fringe benefits as cost share?
LESSON 1 | COURSE CAPSTONE: FINDING ANSWERS IN THE ADMINISTRATIVE REQUIREMENTS
Scenario 4
Facts: A National Park Service (NPS) grantee has developed a

brochure on how to build environmentally safe nature trails
using timber damaged during Hurricane Algernon and slag and
slurry from abandoned mines. Grant funds were used to
develop the brochure and the grantee is selling copies for $5.00
each. The grant is still active. The terms of the grant are silent
as to the disposition of the proceeds from sale of the brochures.
9. What happens to the proceeds? Why?
10. What if the grant period has expired and the grantee continues to earn proceeds?
Scenario 5
Facts: The Department of Education (ED) has made a grant to

the National Educational Research System. The ED grants
official is visiting the grantee but is refused access to the
grantee’s accounting records dealing with personnel costs
charged to the grant.
11. What should the grants official do?
Action Plan
RESOURCE A
ACTION PLAN
OVERVIEW
Participating in a training course is only the first step to mastering a discipline. In order for your
learning to continue, it is important that you put the tools and techniques presented in this course
into action.
PART I: KEY LEARNING POINTS

At the end of each module, time is allotted for you to document ideas that you want to remember.
Module/Lesson Title Key Learning Points
RESOURCE A: ACTION PLAN
PART II: ON THE JOB

Review your key learning points and select three to five that you want to implement when you return
to your job.
Use the table provided on the next page to:
 Prioritize your implementation items
 Write a SMART objective for each item
— Specific
— Measurable
— Attainable
— Realistic
— Time-bound
 Identify the content that supports your objectives
 Document your strategy to achieve your objective
 Set a due date for achievement
Once back on the job, post this action plan in a visible location to remain focused on the completion
of these goals.
ACTION PLAN
Priority Objective Supporting Strategy Due

Content
1.
2.
3.
4.
Priority Objective Supporting Strategy Due

Content
5.
2 CFR 200
Crosswalk
RESOURCE B
2 CFR 200 CROSSWALK
Section Summary Source of Notes Amended
in Guidance Language since
December
19, 2014
SUBPART A - Acronyms and Definitions
200.0-200.99 Identifies the acronyms used in Combined from New and revised Yes
the Uniform Guidance and all definitions
provides the definitions for
commonly used terms
SUBPART B - General Provisions
200.100 Purpose Explains purpose of the Guidance Combined from

all
200.101 Identifies entities governed by Combined from Specifically 09/10/15

Applicability Guidance; exempts certain all references
entitlement programs for ISDEAA
Guidance; and allows for
agencies to apply Guidance to
commercial organizations, foreign
governments, and international
organizations
200.102 Explains procedures to provide 2 CFR 215 (A- References M-13-

Exceptions exceptions to the Guidance in 110) 17
limited circumstances
200.103 Identifies the legal authorities Combined from

Authorities governing the Guidance all
200.104 Identifies the OMB Circulars that Combined from Removes 2 CFR
Supersession have been consolidated into the all Parts 220, 225,
Guidance and 230
200.105 Effects The Guidance takes precedence Revised

on Other over all administrative
Issuances requirements, program manuals,
and handbooks, unless required
by statute
RESOURCE B: 2 CFR 200 CROSSWALK

December
19, 2014
200.106 Agency Federal agencies must codify Revised

Implementation Subpart C through Subpart F into
their regulations
200.107 OMB Outlines OMB's responsibilities Revised

Responsibilities as it relates to implementing the
Guidance
200.108 Inquiries Provides nonfederal entities Revised

appropriate contact information
200.109 Review Requires OMB to review the Revised

Date Guidance every five years
200.110 Effective The Guidance provisions become Revised Provides for a 09/10/15
/ Applicability Date effective on December 26, 2014, three-year grace
and the audit requirements will period to
apply to audits of fiscal years implement new
beginning on or after December procurement
26, 2017 standards.
200.111 English Requires all award documents NEW

Language and applications to be written in
English and requires all currency
amounts be in U.S. dollars
200.112 Conflict Agencies must establish a conflict NEW

of Interest of interest policy for awards, and
recipients must disclose in writing
any potential conflict of interests
200.113 Recipients must indicate in writing NEW 07/22/15

Mandatory all violations of law involving
Disclosures fraud, bribery, or gratuity
violations affecting the award
SUBPART C - Pre-Federal Award Requirements and Contents of Federal Awards
200.200 Purpose Explains the purpose of the Combined from

section all
200.201 Use of References the Federal Grant 2 CFR 215 (A- Fixed amount
Grants, and Cooperative Agreement Act 110) awards described
Cooperative
Agreements, and
Contracts

December
19, 2014
200.202 Explains the procedures in A-89 Agencies must

Requirement to announcing programs and the identify all
Provide Public required elements for the selection criteria
Notice of Federal program description
Financial
Assistance
Programs
200.203 Explains the procedures in 68 FR 37376- Requires funding 7/22/15 and

Announcement of announcing funding opportunities, 37378 opportunities 9/10/15
Funding and identifies the required generally be
Opportunities elements in the announcement announced 60
days before
applications are
due, and no less
than 30 days
before due date
200.204 Federal Requires agencies to develop NEW Competitive

Awarding Agency and implement merit review awards must use
Review of Merit of processes for all competitive a merit review
Proposals awards and mandates agencies process
publish the process in the notice
of funding opportunity
200.205 Federal Requires a pre-award financial NEW Provides 7/22/15 and

Awarding Agency review of applicants guidance to 11/09/15
Review of Risk agencies on how
Posed by to conduct a risk-
Applicants based
assessment
200.206 Standard Requires agencies to use only NEW

Application OMB-approved documents for
Requirements applications and information
collection
200.207 Specific Explains the conditions and 2 CFR 215 (A- Yes
Conditions processes in which agencies may 110)
impose additional award
conditions on high-risk non-
federal entities
200.208 Authorizes agencies to require 2 CFR 215 (A-

Certifications and recipients to submit certifications 110)
Representations

December
19, 2014
200.209 Pre- References cost principles NEW

Award Costs provision (200.458) for pre-award
costs
200.210 Identifies the required elements NEW Requires federal 7/22/15

Information for a grant award awards to use the
Contained in FAIN, document
Federal Awards the approved
indirect cost rate,
and identify award
performance
goals
200.211 Public Mandates agencies to announce NEW Agencies must 7/22/15

Access to Federal all awards and required award publish award
Award Information information on decisions for
www.USASpending.gov awards in excess
of $25,000
200.212 Lists bases for determining if a NEW Added

Reporting a nonfederal entity is qualified or 7/22/15
determination that not qualified for a Federal award
a nonfederal entity and requirements for reporting
is not qualified for such
a Federal award
200.213 States that federal funds cannot NEW 7/22/15

Suspension and be made to nonfederal entities or
debarment contractors that have been
suspended or debarred.
SUBPART D - Post Federal Award Requirements
Subtitle I: Standards for Financial and Program Management
200.300 Statutory Agencies must inform recipients 2 CFR 215 (A- 7/22/15
and National of statutory and public policy 110), A-102
Policy requirements in the award terms
Requirements and conditions
200.301 Outlines procedures to collect 2 CFR 215 (A- Suggests the use
Performance project performance data from 110) of unit cost data
Measures recipients
200.302 Financial Details the requirements for 2 CFR 215 (A-

Management financial management systems 110)

December
19, 2014
200.303 Internal Identifies internal controls A-133 References

Controls nonfederal entities must COSO "Internal
implement Control -
Integrated
Framework"
200.304 Bonds Explains when an agency may 2 CFR 215 (A-

include a provision on bonding 110)
and/or insurance
200.305 Payment Explains the payment process 2 CFR 215 (A- Increases 7/22/15 and
to recipients 110) threshold for 9/10/15
retaining interest
from federal funds
to $500
200.306 Cost Explains cost sharing/matching 2 CFR 215 (A- States that
Sharing or procedures 110) voluntary
Matching committed cost
sharing for
research
proposals is not
expected
200.307 Program Explains program income 2 CFR 215 (A- 8/10/15

Income procedures 110), A-102
200.308 Revisions Explains the process to revise 2 CFR 215 (A- References the 9/10/15
of Budget and budget and program plans 110) definition for the
Program Plans Simplified
Acquisition
Threshold
(200.88)
200.309 Period of Limits charges to an award to 2 CFR 215 (A-

Performance costs incurred during the 110)
performance period or authorized
pre-award costs
Subtitle II: Property Standards
200.310 Outlines insurance requirements 2 CFR 215 (A-

Insurance for federal property 110)
Coverage
200.311 Real Details title, use, and disposition A-102

Property procedures for real property
acquired with a grant

December
19, 2014
200.312 Details the title, use, and 2 CFR 215 (A-

Federally-Owned disposition procedures for 110)
and Exempt federally-owned property
Property
200.313 Details the title, use, A-102 Yes

Equipment management records, and
disposition of equipment
200.314 Supplies Details the title, use, and 2 CFR 215 (A-
disposition of supplies 110)
200.315 Intangible Details the title and use of 2 CFR 215 (A-
Property intangible property 110)
200.316 Property Explains recipient's 2 CFR 215 (A-

Trust Relationship responsibilities for real property, 110)
equipment, and intangible
property that are acquired or
improved with a federal award
Subtitle III: Procurement Standards
200.317 States must follow state law and A-102

Procurements by policies for procuring goods and
States services
200.318 General Explains the procurement 2 CFR 215 (A- Requires 7/22/15
Procurement process and requirements 110) nonfederal entities
Standards to adopt policies
for organizational
conflicts of
interest
200.319 Explains process in awarding A-102 Prohibits

Competition contracts nonfederal entities
from providing
geographical
preference in
evaluating bids or
proposals
200.320 Methods Identifies and explains A-102 Establishes the 9/10/15

of Procurement to procurement methods use of micro-
be Followed purchases;
specifies
procurement
practices

December
19, 2014
200.321 Details procedures to increase A-102

Contracting with contracts to minority- and women-
Small and Minority owned businesses
Businesses,
Women's
Business
Enterprises, and
Labor Surplus
Area Firms
200.322 Explains requirements for state A-102

Procurement of and local governments to adhere
Recovered to the Solid Waste Disposal Act
Materials
200.323 Contract Requires recipients to conduct a A-102

Cost and Price cost or price analysis for every
procurement over the Simplified
Acquisition Threshold
200.324 Federal Requires recipients to provide A-102

Awarding Agency documentation, upon request, to
or Pass-Through the awarding agency to review
Entity Review procurement policies
200.325 Bonding Explains bonding requirements A-102

Requirements for facility improvement contracts
200.326 Contract Requires contracts to contain A-102 Requires new

Provisions certain information provisions to be
included in
contracts
Subtitle IV: Performance and Financial Monitoring and Reporting
200.327 Financial Agencies must use approved A-102

Reporting OMB reporting forms
200.328 Details performance reporting A-102

Monitoring and requirements
Reporting
Program
Performance
200.329 Reporting Details reporting requirements for A-102

on Real Property real property
Subtitle V: Subrecipient Monitoring and Management

December
19, 2014
200.330 Describes the characteristics of A-133 Clarifies 9/10/15

Subrecipient and subrecipients and contractors definitions
Contractor
Determinations
200.331 Establishes requirements for A-133 Explains the 9/10/15

Requirements for pass-through entities for award indirect cost rate
Pass-Through documentation and monitoring of process for
Entities subrecipients subrecipients and
provides
monitoring
guidance for
pass-through
entities
200.332 Fixed Allows pass-through entities, with A-133

Amount prior approval, to make fixed
Subawards amount subawards
Subtitle VI: Record Retention and Access
200.333 Record Requires recipients to retain all A-102 Clarifies the three-
Retention and records for 3 years after year retention
Access submitting final reports and requirement
identifies who can access the
records
200.334 Requests Explains the process to transfer A-102

for Transfers of records from the recipient to the
Records awarding agency
200.335 Methods Details the process to submit A-102 Encourages

for Collection, documentation compliance with
Transmission, and the May 2013
Storage of Executive Order
Information on Making Open
and Machine
Readable the
New Default for
Government
Information
200.336 Access to Identifies the entities that may A-102

Records access recipient records
200.337 Explains the application of and A-102

Restrictions on limitations to the Freedom of
Public Access to Information Act (FOIA) to federal
Records award documents

December
19, 2014
Subtitle VII: Remedies for Noncompliance
200.338 Provides a specific list of options 2 CFR 215 (A-

Remedies for available to federal awarding 110)
Noncompliance agencies and pass-through
entities to address recipient non-
compliance
200.339 Explains the process for federal 2 CFR 215 (A- Written 7/22/15
Termination awarding agencies and pass- 110) notification must
through entities to terminate a be provided to
federal award recipients when
an award is
terminated
200.340 Identifies the required elements 2 CFR 215 (A- 7/22/15

Notification of for a termination notification 110)
termination
requirement
200.341 Provides nonfederal entities the 2 CFR 215 (A-

Opportunities to opportunity to dispute a 110)
Object, Hearings, termination
and Appeals
200.342 Effects of Costs charged to an award during 2 CFR 215 (A-

Suspension and a suspension or after termination 110)
Termination are unallowable
Subtitle VIII: Closeout and Post-Closeout Procedures
200.343 Closeout Describes the responsibilities of 2 CFR 215 (A- Requires federal
federal awarding agencies, pass- 110) awarding
through entities, and nonfederal agencies to close
entities during the closeout out awards within
process one year
200.344 Post- Identifies the parts of the award 2 CFR 215 (A- Cost
Closeout not affected by closeout 110) disallowances to
Adjustments and the award must
Continuing be made within
Responsibilities the record
retention period
200.345 Explains the process federal A-102

Collection of awarding agencies may pursue to
Amounts Due collect outstanding debts from a
recipient

December
19, 2014
SUBPART E - Cost Principles
Subtitle I: General Provisions
200.400 Policy Explains the roles and 2 CFR 220 (A-

Guide responsibilities of federal 21), 2 CFR 225
awarding agencies and non- (A-87)
federal entities regarding cost
principles and creates uniform
cost principles for all entities
200.401 Discusses the role of the cost 2 CFR 220 (A-

Application principles in determining 21), 2 CFR 230
allowable costs (A-87)
Subtitle II: Basic Considerations
200.402 Defines the term "total cost" 2 CFR 220 (A-

Composition of 21), 2 CFR 225
Costs (A-87)
200.403 Factors Discusses the criteria for a cost to Combined from

Affecting be allowable all
Allowability of
Costs
200.404 Discusses the criteria for a cost to Combined from

Reasonable Costs be reasonable all
200.405 Allocable Discusses the criteria for a cost to Combined from

Costs be allocable all
200.406 Defines and explains the term Combined from

Applicable Credits "applicable credits" all
200.407 Prior Identifies the selected items of 2 CFR 220 (A- Identifies when a
Written Approval cost that require prior approval 21), 2 CFR 230 nonfederal entity
(Prior Approval) (A-87) must receive prior
approval
200.408 Limitation Explains the consequences when 2 CFR 220 (A-

of Allowance of statutes limit the allowability of 21), 2 CFR 225
Costs costs (A-87)

December
19, 2014
200.409 Special Provides for exceptions to the 2 CFR 220 (A-

Considerations uniform cost principles for 21), 2 CFR 225
selected entities in certain (A-87)
circumstances
200.410 Identifies the circumstances when 2 CFR 220 (A-

Collection of recipients must refund the federal 21)
Unallowable government
Costs
200.411 Explains the procedures to 2 CFR 220 (A-

Adjustment of recalculate the indirect cost rate 21)
Previously when recipients charge
Negotiated unallowable costs
Indirect (F&A)
Cost Rates
Containing
Unallowable
Costs
Subtitle III: Direct and Indirect (F&A) Costs
200.412 Requires all costs be treated NEW

Classification of consistently in like circumstances
Costs
200.413 Direct Identifies costs that may be 2 CFR 220 (A- Explains when the
Costs charged directly to a federal 21), 2 CFR 230 salaries of
award (A-87) administrative and
clerical staff may
be directly
charged
200.414 Indirect Defines indirect (F&A) costs and 2 CFR 225 (A- Allows select new
(F&A) Costs explains the negotiation process 87), 2 CFR 230 recipients the
(A-87) option of a 10%
de minimis cost
rate, requires all
agencies to
accept negotiated
indirect cost rates,
and allows
recipients to
extend an indirect
cost rate up to
four years

December
19, 2014
200.415 Required Identifies the certificates 2 CFR 220 (A- Certificate

Certificates recipients must sign and submit 21), 2 CFR 225 requirements are
with financial reports and indirect (A-87) new for some
(F&A) cost rate proposals recipients; officials
from the recipient
entity sign the
certificates under
penalty of the
False Claims Act
Subtitle IV: Special Considerations for State, Local, and Indian Tribes
200.416 Cost Explains cost allocation plans 2 CFR 225 (A-

Allocation Plans 87)
and Indirect Cost
Proposals
200.417 Explains indirect cost rates for 2 CFR 225 (A-

Interagency interagency government entities 87)
Service
Subtitle V: Special Considerations for Institutions of Higher Education
200.418 Costs Provides the criteria to allow state 2 CFR 220 (A-
Incurred by States and local governments to charge 21)
and Local fringe benefits for IHEs
Governments
200.419 Cost Discusses the requirements for NEW Raises the

Accounting IHEs to follow CAS and file the threshold for IHEs
Standards and DS-2 disclosure statement to comply with
Disclosure Cost Accounting
Statement Standards to $50
million
Subtitle VI: General Provisions for Selected Items of Cost
200.420 Explains the principles to 2 CFR 220 (A-

Considerations for determine the allowability of costs 21)
Selected Items of for certain items
Costs
200.421 Conditionally allowable 2 CFR 225 (A- Advertising may

Advertising and 87) be used for
Public Relations program outreach
200.422 Advisory Generally unallowable 2 CFR 225 (A-

Councils 87)

December
19, 2014
200.423 Alcoholic Unallowable 2 CFR 225 (A-

Beverages 87)
200.424 Unallowable 2 CFR 220 (A-

Alumni/ae 21)
Activities
200.425 Audit Generally allowable 2 CFR 225 (A-

Services 87)
200.426 Bad Unallowable 2 CFR 225 (A-

Debts 87)
200.427 Bonding Allowable 2 CFR 225 (A-

Costs 87)
200.428 Allowable NEW Allows nonfederal

Collections of entities to charge
Improper the costs incurred
Payments to recover
improper
payments
200.429 Generally unallowable 2 CFR 220 (A-

Commencement 21)
and Convocation
Costs
200.430 Conditionally allowable Combined from Changes

Compensation - all requirements for
Personal Services documenting
personnel
expenses
200.431 Conditionally allowable 2 CFR 230 (A- Includes new 9/10/15

Compensation - 87) restrictions on
Fringe Benefits severance pay
200.432 Generally allowable 2 CFR 230 (A- Includes family-

Conferences 87) friendly policies
200.433 Conditionally allowable 2 CFR 220 (A-

Contingency 21)
Provisions

December
19, 2014

Contributions and 21), 2 CFR 230
Donations (A-87)
200.435 Defense Generally unallowable 2 CFR 220 (A-

and Prosecution 21), 2 CFR 225
of Criminal and (A-87)
Civil Proceedings,
Claims, Appeals,
and Patent
Infringements

Depreciation 21)
200.437 Generally allowable 2 CFR 220 (A- Eliminates

Employee Health 21) references to
and Welfare employee morale
costs

Entertainment 21)
Costs

Equipment and 21), 2 CFR 225
Other Capital (A-87)
Expenditures
200.440 Generally allowable NEW

Exchange Rates
200.441 Fines, Generally unallowable 2 CFR 220 (A- Includes tribal

Penalties, 21) governments
Damages, and
Other Settlements
200.442 Fund Generally unallowable 2 CFR 225 (A-

Raising and 87)
Investment
Management
Costs
200.443 Gains Conditionally allowable 2 CFR 225 (A-

and Losses on 87)
Disposition of
Depreciable
Assets

December
19, 2014
200.444 General Generally unallowable 2 CFR 225 (A- Indian Tribes and
Government 87) Councils of
Expenses Governments may
include 50%
salaries and
expenses, related
to grant
administration, of
chief executives in
indirect cost pool
without
documentation
200.445 Goods or Generally unallowable 2 CFR 220 (A-

Services for 21)
Personal Use
200.446 Idle Conditionally allowable 2 CFR 225 (A- Allows for

Facilities and Idle 87) fluctuations in
Capacity capacity

Insurance and 21), 2 CFR 225
Indemnification (A-87)
200.448 Conditionally allowable NEW

Intellectual
Property
200.449 Interest Conditionally allowable Combined from Patents and 9/10/15

all computer
software included
as intangible
assets starting
January 1, 2016.
200.450 Lobbying Generally unallowable 2 CFR 220 (A- Expands upon the
21), 2 CFR 225 definition and
(A-87) examples of
lobbying
200.451 Losses Unallowable 2 CFR 220 (A-

on Other Federal 21)
Awards or
Contracts
200.452 Generally allowable 2 CFR 230 (A-

Maintenance and 87)
Repair Costs

December
19, 2014
200.453 Material Generally allowable 2 CFR 230 (A-

and Supplies 87)
Costs, Including
Costs of
Computing
Devices
200.454 Conditionally allowable 2 CFR 230 (A- Costs of

Membership, 87) membership in
Subscriptions, and organizations
Professional whose primary
Activity Costs purpose is
lobbying is
unallowable

Organization 87)
Costs
200.456 Conditionally allowable 2 CFR 230 (A- Applicable to all

Participant 87) non-federal
Support Costs entities
200.457 Plant and Generally allowable 2 CFR 230 (A-

Security Costs 87)
200.458 Pre- Conditionally allowable 2 CFR 230 (A-

Award Costs 87)

Professional 87)
Service Costs
200.460 Proposal Conditionally allowable 2 CFR 220 (A- Only allowable as

Costs 21) indirect (F&A)
costs
200.461 Generally allowable 2 CFR 225 (A- Research

Publication and 87) publication costs
Printing Costs may be charged
before closeout

Rearrangement 87)
and Reconversion
Costs

December
19, 2014
200.463 Conditionally allowable 2 CFR 220 (A- "Help Wanted"

Recruiting Costs 21) requirements
removed; short-
term visas
generally
allowable
200.464 Conditionally allowable 2 CFR 230 (A- Ownership costs

Relocation Costs 87) of vacant homes
of Employees allowable only for
six months
200.465 Rental Conditionally allowable Combined from Home office

Costs of Real all workspace rental
Property costs are
unallowable

Scholarships and 21)
Student Aid Costs
200.467 Selling Conditionally allowable 2 CFR 230 (A-

and Marketing 87)
Costs

Specialized 21)
Service Facilities
200.469 Student Generally unallowable 2 CFR 220 (A-

Activity Costs 21)
200.470 Taxes Generally allowable 2 CFR 220 (A- Costs for VAT are
(Including Value 21), 2 CFR 225 allowable
Added Tax) (A-87), NEW

Termination Costs 87)
200.472 Training Generally allowable 2 CFR 230 (A-

and Education 87), 2 CFR 225
Costs (A-87)
200.473 Generally allowable 2 CFR 220 (A-

Transportation 21)
Costs

December
19, 2014
200.474 Travel Conditionally allowable 2 CFR 220 (A- Includes family-

Costs 21) friendly policies
200.475 Trustees Generally allowable 2 CFR 220 (A- Nonprofit

21) organizations can
charge travel
costs for trustees
and directors
SUBPART F - Audit Requirements
Subtitle I: General
200.500 Purpose Identifies the objectives in A-133

creating uniform standards for
audit requirements
Subtitle II: Audits
200.501 Audit Explains the single audit A-133, A-50 Raises the single
Requirements requirements audit threshold to
$750,000
200.502 Basis for Explains how to calculate the total A-133

Determining amount of federal funds
Federal Awards expended
Expended
200.503 Relation Explains the process for federal A-133

to Other Audit awarding agencies to conduct
Requirements other audits outside the single
audit
200.504 Requires annual audits for A-133

Frequency of applicable entities and explains
Audits how biennial audits should be
conducted
200.505 Identifies the consequences for a A-133

Sanctions recipient that does not conduct a
required audit
200.506 Audit References the selected item of A-133

Costs cost for audit services

December
19, 2014
200.507 Program- Explains the process for program- A-133 Requires auditors
Specific Audits specific audits and how such an to follow program-
audit should be conducted if a specific audit
program-specific audit guide is guides, found in
unavailable the compliance
supplement
beginning in 2014,
and conduct
audits in
compliance with
GAGAS
Subtitle III: Auditees
200.508 Auditee Explains the responsibilities of the A-133

Responsibilities auditee
200.509 Auditor Explains the requirements and A-133 Allows auditees to

Selection restrictions in selecting an auditor consider peer
reviews during the
auditor selection
process
200.510 Financial Identifies the required elements A-133

Statements for financial statements and the
schedule of expenditures of
federal awards
200.511 Audit Discusses the auditee's A-133

Findings Follow- responsibility to correct audit
Up findings
200.512 Report Explains the process of A-133 Requires the

Submission submitting the single audit auditee to certify
reporting package and the the audit package
required elements of the reporting does not contain
package Personally
Protected
Information and
provides an
exception for
Indian tribes to
publish
documents on the
FAC
Subtitle IV: Federal Agencies

December
19, 2014
200.513 Explains the responsibilities of the A-133 Describe the roles

Responsibilities cognizant agency for audit and and
federal awarding agencies in responsibilities for
regard to the single audit new federal
agency officials
Subtitle V: Auditors
200.514 Scope of Identifies the guiding principles A-133

Audit for audits, explains how auditors
should test internal controls and
ensure the auditee has complied
with all requirements
200.515 Audit Identifies and explains the A-133

Reporting required elements of the single
audit report
200.516 Audit Defines and explains the types of A-133 Raises the
Findings audit findings and explains how threshold for
audit findings should be reported questioned costs
to $25,000
200.517 Audit Requires auditors to retain audit A-133

Documentation documents for three years and
identifies the entities that may
have access to the documents
200.518 Major Provides the process in A-133 Alters the process

Program determining which programs in major program
Determination should be treated as major determination
programs
200.519 Criteria Explains how the level of risk for A-133

for Federal federal programs must be
Program Risk determined
200.520 Criteria Identifies the criteria an auditee A-133 Adds new

for a Low-Risk must meet to qualify as a low-risk requirements,
Auditee auditee e.g., the auditee
must have
submitted
previous single
audits on time,
and the auditee
cannot use
biennial audits to
qualify as low-risk

December
19, 2014
Subtitle VI: Management Decisions
200.521 Explains the responsibilities of A-133 Requires the

Management federal awarding agencies and auditee to initiate
Decision pass-through entities to issue and proceed with
management decisions on audit corrective action
findings as rapidly as
possible
APPENDICES
Appendix I - Full Identifies and explains the 68 FR 37376- 7/22/15

Text of Notice of required elements for the notice 37378
Funding of funding opportunities
Opportunities
Appendix II - Identifies the required elements Combined from

Contract for a contract agreement regulations and
Provisions for statutes
Nonfederal Entity
Contracts Under
Federal Awards
Appendix III - Discusses the indirect (F&A) cost 2 CFR 220 (A- 9/10/15
Indirect (F&A) rate provisions for IHEs 21)
Cost Identification
and Assignment,
and Rate
Determination for
Institutions for
Higher Education
(IHEs)
Appendix IV - Discusses the indirect (F&A) cost 2 CFR 230 (A- 9/10/15
Indirect (F&A) rate provisions for nonprofits 87)
Cost Identification
and Assignment,
and Rate
Determination for
Nonprofit
Organizations
Appendix V - Discusses cost allocation plans 2 CFR 225 (A- 9/10/15

State/Local for state and local governments 87)
Government and and Indian tribes
Indian Tribe -Wide
Central Service
Cost Allocation
Plans

December
19, 2014
Appendix VI - Discusses how public assistance 2 CFR 225 (A-

Public Assistance programs develop and implement 87)
Allocation Plans cost allocation plans
Appendix VII - Discusses the indirect (F&A) cost 2 CFR 225 (A-
State and Local rate provisions for state and local 87)
Government and governments and Indian tribes
Indian Tribe
Indirect Cost
Proposal
Appendix VIII - Identifies the nonprofit 2 CFR 220 (A-

Nonprofit organizations that are treated as 21)
Organizations for-profit entities for the purpose
Exempted from of the applicability of the cost
Subpart E: Cost principles
Principles
Appendix IX - Exempts hospitals from the cost 45 CFR 75,

Hospital Cost principles in the Uniform Appendix E
Principles Guidance
Appendix X- Audit Provides location information for A-133

Data Collection the SF-SAC
Form (Form SF-
SAC)
Appendix XI - Provides location information for A-133

Compliance the Compliance Supplement Compliance
Supplement Supplement
Appendix XII - Details the T&C that must be NEW Added

Award Term and included for awards that may total 7/22/15
Condition for over $500,000
Recipient Integrity
and Performance
Matters
Agency-Specific
Exceptions
RESOURCE C
AGENCY-SPECIFIC EXCEPTIONS
AGENCY-SPECIFIC EXCEPTIONS
The following table identifies agency-specific exceptions to the Uniform Guidance. Unless
otherwise noted, an agency's implementing regulations are found in 2 CFR.
Agency Exceptions
Agency for § 700.3 Applicability

International
Development
§ 700.4 Exceptions
§ 700.8 Payment
§ 700.9 Property Standards
§ 700.12 Contract provisions
Corporation for § 2205.306 Cost sharing or Matching

National and
Community Service
§ 2205.307 Program Income
§ 2205.332 Fixed amount subawards
§ 2205.414 Indirect (F&A) costs
Department of §415.1 Competition in the awarding of discretionary grants and cooperative

Agriculture agreements.
§416.1 Special Procurement Provisions
Department of §1103.100 Applicability of 2 CFR part 200 to requirements for recipients in DoD
Defense Components’ terms and conditions
§1103.200 Exception for small awards
§1103.205 Timing of payments made using the reimbursement method
RESOURCE C: AGENCY-SPECIFIC EXCEPTIONS
Agency Exceptions
§1103.210 Management of federally owned property for which a recipient is

accountable
§1103.215 Intangible property developed or produced under an award or subaward
§1103.220 Debarment and suspension requirements related to recipients’

procurements
§1103.225 Debt collection
Department of §3474.5 How exceptions are made to 2 CFR part 200

Education
§3474.10 Clarification regarding 2 CFR 200.207
Department of § 910.122 Applicability

Energy
§ 910.130 Cost sharing (EPACT)
§910.354 Payment
§910.356 Audits
Department of 45 CFR part 75, HHS incorporates the guidance in 2 CFR 200
Health and Human
Services
45 CFR 75.1, Acronyms
45 CFR 75.2, Definitions
45 CFR 75.104, Suppresses 45 CFR 74 and 92
45 CFR 75.106, Implementation
45 CFR 75.108, Addresses whom changes for HHS regulation should be addressed
45 CFR 75.109, HHS’ review period for regulations
45 CFR 75.112, HHS’ conflict of interest policies and disclosure criteria
45 CFR 75.205, adds text at the end of subsection (a, 200.205)to reference
suspension and debarment regulations
45 CFR 75.206, adds subsection (c ) (d) to 200.206 to specify the forms required.
Agency Exceptions
45 CFR 75.208, adds new subsections (a) and (b) to 200.208 to reference 45 CFR
part 87 and §75.206(d)(2)
45 CFR 75.212, changes “2CFR part 180” to read “2 CFR parts 180 and 376”
45 CFR 75.213, References The Metric Conversation Act and HHS’ use of Executive
Order 12770
45 CFR 75.214, References lobbying restrictions in 45 CFR part 93
45 CFR 75.215, References provisions for awards to Commercial Organizations
45 CFR 75.216, References provisions for awards to Federal Agencies
45 CFR 75.217, References standards for faith-based organizations in 45 CFR part

87
45 CFR 75.305, adds to the end of 2 CFR 200.305 subsection (b)(5)(ii) “(See 45 CFR
part 30).”
45 CFR 75.307, Revises 2 CFR 200.307 subsection (c)
45 CFR 75.308, (1) Add subsections to 2 CFR 200.308: (c)(9) through (11) and (2)
add at the end, new subsection (j)
45 CFR 75.309, Articulates the use of funds within a period of performance
45 CFR 75.316, Articulates HHS’ policy on property management standards and

procedures
45 CFR 75.317, Adopts 2 CFR 200.310 inserting “other” preceding “property owned”
in the first sentence
45 CFR 75.318, modifies 2 CFR 200.311
45 CFR 75.320, modifies 2 CFR 200.313
45 CFR 75.322, modifies 2 CFR 200.315
45 CFR 75.327, modifies 2 CFR 200.327
45 CFR 75.329, adopts 2 CFR 200.320 and changes the title.
45 CFR 75.334, adopts 2 CFR 200.325 and adds new subparagraph (d)
45 CFR 75.371, modifies 2 CFR 200.338
45 CFR 75.374, adopts 2 CFR 200.341 adding an additional subparagraph(b)
Agency Exceptions
45 CFR 75.381, Adopts 2 CFR 200.343 and in paragraph (g) changes “one year” to
“180 calendar days”
45 CFR 75.391, Adopts 2 CFR 200.345 and adds reference
45 CFR 75.407, Adopts 2 CFR 200.407 with the additional subparagraphs (b) and (c)
45 CFR 75.439, Adopts 2 CFR 200.439 and amends subsection (a) to remove
definition numbers
45 CFR 75.476, Articulates independent research and development costs
45 CFR 75.501, Adopts 2 CFR 200.501 by adding new subparagraphs (i) and (j) to
articulate the audit options and exemptions for commercial organizations
Department of the § 1402.101 To whom does this part apply?

Interior
§ 1402.102 Do DOI financial assistance policies include any exceptions to 2 CFR

200?
Department of § 2800.313 Equipment

Justice
§ 2800.314 Supplies
Department of Labor §2900.1 Budget
§2900.2 Non-Federal entity
§2900.3 Questioned cost
§2900.4 Adoption of 2 CFR Part 200
§2900.5 Federal awarding agency review of merit of proposals
§2900.6 Advance Payment
§2900.7 Payment
§2900.8 Cost sharing or matching
§2900.9 Revision of budget and program plans
§2900.10 Prior approval requests
§2900.11 Revision of budget and program plans including extension of the period of
performance
Agency Exceptions
§2900.12 Revision of budget and program plans approval from Grant Officers
§2900.13 Intangible property
§2900.14 Financial reporting
§2900.15 Closeout
§2900.16 Prior written approval (prior approval)
§2900.17 Adjustment of negotiated IDC rates
§2900.18 Contingency provisions
§2900.19 Student activity costs
§2900.20 Federal Agency Audit Responsibilities
§2900.21 Management decision
Department of State § 600.101 Applicability
§600.407 Prior written approval (prior approval)
Department of § 1201.80 Program income

Transportation
§ 1201.206 Standard application requirements
§ 1201.313 Equipment
§ 1201.317 Procurements by States
§ 1201.327 Financial reporting
Department of the § 1000.306 Cost sharing or matching

Treasury
§ 1000.336 Access to records
Environmental §1500.2 Applicability

Protection Agency
§1500.3 Exceptions
Agency Exceptions
§1500.5 Fixed Amount Awards
§1500.6 Retention requirements for records
§1500.7 Program Income
§1500.8 Revision of budget and program plans
§1500.9 General Procurement Standards
§1500.10 Use of the same architect or engineer during construction
National Aeronautics § 1800.3 Applicability

and Space
Administration
National Archives § 2600.101 Indirect costs exception to 2 CFR 200.414

and Records
Administration
National Science § 2500.100 Adoption of 2 CFR Part 200

Foundation
Small Business § 2701.74 Pass-through entity

Administration
§ 2701.92 Subaward
§ 2701.93 Subrecipient
§ 2701.414 Indirect (F&A) Costs
§ 2701.503 Relation to other audit requirements
EPA Conflict of
Interest Policy
RESOURCE D
EPA CONFLICT OF INTEREST
POLICY
EPA's Final Financial Assistance Conflict of Interest Policy | Understanding, Managing, and Applying for EP...
EPA's Final Financial Assistance Conflict of

Interest Policy
Related Information
• EPA's Revised Interim Financial Assistance Conflict of Interest Policy applicable (05/22/2015)
• EPA's Interim Financial Assistance Conflict of Interest Policy (12/26/2014 to 05/22/2015)
On this page:
• 1.0 Purpose
• 2.0 Applicability, Effective Date and Relationship to other Policies
• 3.0 Definitions
• 4.0 Situations Requiring Disclosure
• 5.0 Disclosure requirements by applicant/recipient type
• 6.0 Disclosure Requirements
• 7.0 Timing of disclosures
• 8.0 Content of disclosures
• 9.0 EPA actions
1.0 Purpose
As required by Title 2 of the Code of Federal Regulations (CFR) section 200.112, EPA has established the
following final policy governing disclosure of actual and potential conflicts of interest (COI Policy) by
applicants for, and recipients of, federal financial assistance awards from EPA. This policy is intended to
prevent personal and organizational conflict of interests in the award and administration of EPA financial
assistance.
2.0 Applicability, Effective Date and Relationship to other Policies
This COI Policy, except as noted below, applies to all individuals and non-Federal entities requesting and
receiving EPA financial assistance in the form of new initial awards or incremental/supplemental funding
on or after October 1, 2015 and supersedes EPA’s May 22, 2015 Revised Interim COI Policy and
December 26, 2014 Interim COI Policy. It is distinct from and different than EPA policies governing
scientific integrity and those implementing the Standards of Ethical Conduct for Employees of the
Executive Branch. In addition, nothing in this COI Policy supersedes the conflict of interest provisions of
Page 1 of 6
EPA Order 5700.5A1, Policy for Competition of Assistance Agreements (02/06/2014) (EPA's Competition
Policy).
This COI Policy does not apply to:
(a) Awards to foreign governments and international organizations covered by the International
Organizations Immunity Act (e.g. the World Health Organization).
(b) Internal transfers of funds within the recipient’s organization (e.g. between departments of a tribal
government or institution of higher education).
3.0 Definitions
Applicant: An individual (including applicants for competitive fellowships under 40 CFR Part 46) or non-
Federal entity who submits a competitive proposal and/or final Standard Form 424, Application for Federal
Assistance (SF-424) (PDF) (3 pp, 265 K, About PDF), following selection by EPA to receive a federal
financial assistance award under competitive or noncompetitive procedures.
Conflicts of Interest (COI): An actual or potential COI situation described at 2 CFR 200.318(c)(1) or (c)(2)
or equivalent provisions of the Procurement Standards of 40 CFR Part 30 and 40 CFR 31.36 for recipients
who have delayed compliance with the Procurement Standards of 2 CFR Part 200. 1 The term also
includes situations that create, or may create, an unfair competitive advantage, or the appearance of such,
for an applicant in competing for federal financial assistance from EPA.
COI Point of Contact: The individual designated by the applicant or recipient to disclose and resolve COI
for Federal financial assistance awards or subawards. A COI Point of Contact for applicants for
competitive funding may be the Authorized Representative specified on the Standard Form 424,
Application for Federal Financial Assistance, unless the applicant designates another official. Applicants
for noncompetitive funding and recipients may designate the Authorized Representative or another
employee or officer of the Non-Federal Entity or another entity (e.g. consultant or attorney) expressly
authorized by the Non-Federal Entity to speak on its behalf.
Federal Financial Assistance: This term is defined at 2 CFR 200.40.
Non-Federal Entity: This term is defined at 2 CFR 200.69.
Immediate Family: This term is defined at 2 CFR 200.465(c)(4).
Individual: A natural person.
Pass-through entity: This term is defined at 2 CFR 200.74.
Recipient: This term is defined at 2 CFR 200.86 and for the purposes of this COI Policy also includes
individuals who receive awards under EPA statutes authorizing direct Federal financial assistance to
individuals.
State: This term is defined at 2 CFR 200.90. For the purposes of this COI Policy, institutions of higher
education that are instrumentalities of a state under their state’s laws are subject to the same disclosure
obligations as state government agencies.
Page 2 of 6
Subaward: This term is defined at 2 CFR 200.92. For the purposes of this COI Policy subawards do not
include loans, loan guarantees, interest subsidies and principal forgiveness, purchases of insurance or
similar transactions entered into with borrowers by recipients of revolving loan fund capitalization grants
or other EPA financial assistance agreements where Agency funds may be used for lending activities.
However, the terms and conditions of these EPA assistance agreements may include COI provisions
applicable to transactions with borrowers.
Subrecipient: This term is defined at 2 CFR 200.93 and for the purpose of this COI Policy also includes
individuals (who are not program beneficiaries) who receive subawards.
4.0 Situations Requiring Disclosure
This policy addresses the following COI situations:
(a) COIs related to Competitive Assistance Agreements. All EPA solicitations will include a clause
requiring the applicant’s COI Point of Contact to notify the EPA contact identified in Section VII of the
solicitation of any actual or potential conflict of interest that they are aware of that may provide the
Applicant with an unfair competitive advantage in competing for EPA financial assistance awards.
Examples of an unfair competitive advantage include but are not limited to situations in which an EPA
employee reviewed and commented on or drafted all or part of an applicant’s proposal. EPA will promptly
take appropriate action upon receiving any such notification from the Applicant. In addition, assistance
agreement awards made under the solicitation will include a term and condition notifying recipients that
they must have procedures in place to ensure that they address, disclose and resolve actual and/or potential
conflicts of interest as described in this COI Policy in awarding subawards and/or contracts under the EPA
assistance agreement award.
(b) COIs related to the selection, award and administration of recipient or subrecipient contracts.
Any COI described at 2 CFR 200.318(c)(1), 40 CFR 30.42, or 40 CFR 31.36(b)(3), as applicable,
involving a procurement contract regardless of amount including, but not limited to, consulting fees or
other compensation paid by contractors to employees, officers, agents of the recipient or subrecipient
and/or members of their Immediate Families.
(c) Recipient or subrecipient procurement actions raising organizational COIs with a parent,
affiliate or subsidiary organization that is not a State, local government or Indian Tribe. Any
organizational COI described at 2 CFR 200.318(c)(2) or governed by 40 CFR 40.43 or 40 CFR 31.36(c),
as applicable, involving a procurement contract regardless of amount. Organizational conflicts of interest
means that because of relationships with a parent company, affiliate, or subsidiary organization, the non-
Federal entity is unable or appears to be unable to be impartial in conducting a procurement action
involving a related organization. For the purpose of this disclosure requirement, the non-Federal entity
should use the definition of affiliate at 2 CFR 180.905 for guidance.
(d) Subaward COIs. Consistent with OMB’s Frequently Asked Questions on 2 CFR 200.112 (PDF) (30
pp, 773 K, About PDF), any COI in the award, administration, or monitoring of subawards regardless of
amount that would arise due to:
i. COIs similar to those described at 2 CFR 200.318(c)(1) including consulting fees or other compensation
paid to employees, officers, agents of a pass-through entity or members of their Immediate Families by
subrecipients or their procurement contractors receiving EPA funding under a subaward.
Page 3 of 6
ii. Organizational COI similar to those described at 2 CFR 200.318(c)(2) between the subrecipient or other
subrecipients receiving EPA funding under a subaward.
5.0 Disclosure requirements by applicant/recipient type
(a) Consistent with 2 CFR 200.317, Authorized Representatives or other designated officials for states
must provide COI disclosures to EPA only when competing for EPA funding under the solicitation
provision described in Section 4.0(a) or as a Pass-Through Entity under 5.0(d).
(b) Individuals applying for EPA Fellowship awards under 40 CFR Part 46 are only subject to the
disclosure requirements under the competitive solicitation provision described in Section 4.0(a). They are
not subject to any other COI disclosure requirements.
(c) Non-federal entities (other than states) and individuals (other than fellowship recipients) must provide
COI disclosures to EPA under the situations described in Section 4.0(a) through 4.0(d).
(d) Recipients, including states, acting as a Pass-through entity must require subrecipients receiving or
being considered for a subaward to disclose to the recipient the COI situations described in Section 4.0(b),
(c) and (d). The Pass-through entity must in turn disclose the COI to EPA.
(e) EPA only requires that Applicants/Recipients disclose any COI, if any, as described in Section 6.0. If
Applicants/Recipients do not discover a COI, they do not need to advise EPA of the results of their
inquiries.
6.0 Disclosure Requirements
(a) Under Section 4.0(a), the Applicant’s COI Point of Contact need only disclose to EPA situations that
they are personally aware of at the time the applicant submits its competitive proposal to EPA or
subsequently becomes aware of prior to being notified by EPA of the outcome of the competition.
Additionally, EPA’s assistance agreement with successful applicants will include a term and condition
requiring the recipient to notify EPA of any competition related COI described in Section 4.0(a) of the COI
Policy that the COI Point of Contact discovers after award. EPA does not require that COI Points of
Contact make additional inquiries regarding situations covered in Section 4.0(a).
(b) Recipients (other than states and fellowship recipients under 40 CFR Part 46) must have systems in
place to address, resolve, and disclose to EPA the COI situations described in Sections 4.0(b) and (c), and
(d) that affect any contract or subaward funded under an EPA financial assistance agreement in accordance
with the terms and conditions of their award.
(c) Pass through entities, including states, must impose COI disclosure requirements on Non-federal
entities and individuals being considered for, or receiving subawards, that are at a minimum in accordance
with sections 5.0(d) and 7.0(c) of this COI Policy.
7.0 Timing of disclosures
Page 4 of 6
(a) For awards EPA will make competitively, the Applicant’s COI Point of Contact must provide
disclosures, if any, covered by Section 4.0(a) to EPA’s point of contact identified in Section VII of the
solicitation within 10 calendar days of becoming aware of the COI.
(b) For COI disclosures required by Sections 4.0(b), (c), and (d) recipients must provide their COI
disclosure, as applicable, within 30 calendar days of discovery of the COI to EPA in accordance with the
terms and conditions of their award.
(c) Pass-through entities (including states) must require that subrecipients disclose COI described in
Sections 4.0(b), (c), and (d) to them within 30 calendar days of discovery. In turn, Pass-through entities
must disclose subrecipient COI’s to EPA within 30 calendar days of receiving notification of a COI by the
subrecipient unless the pass-through entity requests that EPA grant a longer period of time to resolve the
subrecipient COI.
8.0 Content of disclosures
(a) All COI disclosures must be in writing preferably through email communication.
(b) In situations covered under Section 4.0(a), applicants must describe the unfair competitive advantage
(e.g., proposal preparation assistance they received from an EPA employee and the approximate time
frame in which the assistance was provided) circumstances.
(c) For the COIs described in Sections 4.0(b), 4.0(c) and 4.0(d), recipients must provide EPA with any
information regarding measures to eliminate, neutralize, mitigate or otherwise resolve the COI.
9.0 EPA actions
(a) EPA will notify applicants of their COI disclosure obligations prior to award through the solicitation
clause described in 4.0(a) and include a term and condition in all awards describing the recipients COI
disclosure obligations under 4.0(b), 4.0(c) and 4.0(d) after award. The notifications and terms and
conditions will identify EPA’s point of contact for COI disclosures.
(b) The Agency will review COI disclosures under 4.0(b), 4.0(c) and 4.0(d) and measures recipients
propose to resolve the COI and advise applicants/recipients of EPA’s determination on the effectiveness of
the measures within 30 calendar days of disclosure unless a longer period of time is necessary due to the
complexity of the situation. Disclosure of a potential COI will not necessarily result in EPA disallowing
costs, with the exception of procurement contracts that the Agency determines violate 2 CFR 200.318(c)(1)
or (2), provided the recipient notifies EPA of measures the recipient or subrecipient has taken to eliminate,
neutralize or mitigate the conflict of interest when making the disclosure.
1 EPA implemented OMB Circular A-110 (2 CFR Part 215) in 40 CFR Part 30 and OMB Circular A-102
in 40 CFR Part 31.
Page 5 of 6
Last updated on February 25, 2016
Page 6 of 6
CFDA (Assistance
Listing) Notice and
NOFO for Urban
Indian Health
Services
RESOURCE E
CFDA (ASSISTANCE LISTING)
NOTICE AND NOFO FOR URBAN
INDIAN HEALTH SERVICES
93.193 - Urban Indian Health Services - CFDA: Programs
Urban Indian Health Services

The Indian Health Service IHS
Number: 93.193
Agency: Department of Health and Human Services
Office: Indian Health Service
PROGRAM INFORMATION
Authorization (040):
Indian Health Care Improvement Act, Executive Order Section 503, Title V, Section 511, Public Law 94-437;
Indian Health Care Improvement Act, Title V, Public Law 102-572.
Objectives (050):
Grants provide health-related services to Urban Indians including: (1) Alcohol and substance abuse prevention,
treatment, rehabilitation, and education; (2) Mental health needs assessment and services; (3) Health promotion
and disease prevention services; (4) Immunization services; and (5) HIV/AIDS prevention and care. Cooperative
Agreement provides services and advocacy for Urban Indian Organizations including: (1) Public policy; (2)
Research and data; (3) training and technical assistance; (4) Education, public relations and marketing.
Types of Assistance (060):
Cooperative Agreements; Project Grants
Uses and Use Restrictions (070):
These grants are limited to established urban Indian health services. The recipient organization must be an urban
Indian organization with whom the Secretary has entered into a contract or grant under Title V of the Indian Health
Care Improvement Act (25 U.S.C. 1651 et seq). 100% funds under the Urban Indian Health Program are
discretionary activities.
Eligibility Requirements (080)
Applicant Eligibility (081):

Urban Indian organizations, as defined by 25 U.S.C. 1603(29), operating a Title V Urban Indian Health Program
that currently has a grant or contract with the IHS under Title V of the Indian Health Care Improvement Act, (Pub.
L. 93-437).
Beneficiary Eligibility (082):

Urban Indians residing in the urban centers in which the organization is located.
Credentials/Documentation (083):
The applicant must provide documentation of: (1) Nonprofit status; and (2) that it has a current contract or grant
with the Indian Health Service under Title V of the Indian Health Care Improvement Act. Costs will be determined
in accordance with 45 C.F.R. Part 75, Subpart E. 2 CFR 200, Subpart E - Cost Principles applies to this program.
Application and Award Process (090)
Page 1 of 4
Preapplication Coordination (091):

Preapplication coordination is not applicable. Environmental impact information is not required for this program.
This program is excluded from coverage under E.O. 12372.
Application Procedures (092):

2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
applies to this program. 45 C.F.R. Part 75, Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for HHS Awards (Uniform Guidance) apply to this program
Award Procedure (093):

Grants are awarded to all eligible organizations based on a competitive grant process. Applications are processed
and grants are awarded by Indian Health Service Headquarters. Funding level available to an organization is
based on specific criteria in the Indian Health Care Improvement Act to include size of urban Indian population,
accessibility to, and utilization of, other health resources available to that population and identification of need for
services.
Deadlines (094):
Contact the headquarters or regional office, as appropriate, for application deadlines.
Range of Approval/Disapproval Time (095):

From 60 to 90 days. Grants are approved or disapproved within 90 days of receipt of grant applications by the
Indian Health Service, Division of Grants Management.
Appeals (096):
Not Applicable.
Renewals (097):
Renewal of multi-year cooperative agreements is on a year-to-year basis and requires the submission of
continuation applications.
Assistance Consideration (100)
Formula and Matching Requirements (101):

This program has no statutory formula.
This program has no matching requirements.
This program does not have MOE requirements.
Length and Time Phasing of Assistance (102):

Grants will be awarded for project periods of up to 5 years. Method of awarding/releasing assistance: quarterly.
Post Assistance Requirements (110)
Reports (111):
No program reports are required. Grantees will be required to submit quarterly Federal Financial Report (SF-425
or FFR) to the Division of Payment Management Branch. Depending on services provided, progress and financial
reports will be required either quarterly or semi-annually with final performance and financial status reports due 90
after the end of the project period. Grantees will be required to submit quarterly Federal Financial Report (SF-425
or FFR) to the Division of Payment Management Branch. IHS grants are monitored by the Division of Grants
Management for financial compliance and by the IHS Program Staff for programmatic compliance.
Audits (112):
Page 2 of 4
In accordance with the provisions of 2 CFR 200, Subpart F - Audit Requirements, non-Federal entities that expend
financial assistance of $750,000 or more in Federal awards will have a single or a program-specific audit
conducted for that year. Non-Federal entities that expend less than $750,000 a year in Federal awards are exempt
from Federal audit requirements for that year, except as noted in 2 CFR 200.503. In addition, grantees are subject
to site visits and audits by the Department of Health and Human Services (DHHS) and other Federal officials.
Records (113):
DHHS and the Comptroller General of the United States or any of their authorized representatives, shall have the
right of access to any books, documents, papers, or other records of a grantee, subgrantee, contractor, or
subcontractor, which are pertinent to the grant in order to make audits, examinations, excerpts, and transcripts.
Grantees are required to maintain grant accounting records for 3 years after the end of a budget period. If any
litigation, claim, negotiation, audit or other action involving the records has been started before the expiration of
the 3-year period, the records shall be retained until completion of the action and resolution of all issues which
arise from it, or until the end of the regular 3-year period, whichever is later.
Financial Information (120)
Account Identification (121):

75-0390-0-1-551.
Obligations (122):
(Cooperative Agreements (Discretionary Grants)) FY 14 $1,021,176; FY 15 est $1,096,176; and FY 16 est
$1,096,176 - Obligations for Urban Indian Education and Research program. (Project Grants (Discretionary)) FY
14 $8,326,505; FY 15 est $8,326,505; and FY 16 est $8,326,505 - Obligations for Urban Indian Health Programs 4
-in-1 program. (Project Grants (Discretionary)) FY 14 $400,000; FY 15 est $125,000; and FY 16 est $125,000 -
Obligations for Urban Indian Health Programs Title V HIV/AIDs program.
Range and Average of Financial Assistance (123):

$149,950 to $1,096,176; $280,678.
Program Accomplishments (130):

Not Applicable.
Regulations, Guidelines, and Literature (140):

Specific program guidelines, including applicable sections of Public Law 94-437, as amended; 45 CFR 74 and 92;
and the HHS Grants Policy Statement, dated 1/07.
Information Contacts (150)
Regional or Local Office (151) :

None. Program Contact: Mr. Rick Mueller, Health Systems Specialist, Office of Urban Indian Health Programs,
Indian Health Service, 801 Thompson Avenue, Suite 200, Rockville, MD 20852. Telephone: (301) 443-4680.
Grants Management Contact: Ms. Tammy Bagley, Acting Director, Division of Grants Management, Indian Health
Service, 801 Thompson Avenue, Suite TMP 360, Rockville, MD 20852. Telephone: (301) 443-5204, Fax (301) 443
-9602. Use the same number for FTS.
Headquarters Office (152):

Grants Policy Office, 801 Thompson Avenue, Suite TMP 360, Rockville, Maryland 20852 Email:
grantspolicy@ihs.gov Phone: (301) 443-5204
Page 3 of 4
Website Address (153):

http://www.ihs.gov
Related Programs (160):

Not Applicable.
Examples of Funded Projects (170):

Not Applicable.
Criteria for Selecting Proposals (180):

Proposals will be reviewed by staff of the Indian Health Service to ensure compliance with the following: (1) Size
of the urban Indian population; (2) accessibility to, and utilization of, other health resources available to such
population; (3) duplication of existing Indian Health Service or other Federal grants or contracts; (4) capability of
the organization to adequately perform the activities required under the grant; (5) satisfactory performance
standards for the organization in meeting the goals; (6) identification of need for services; and (7) proposed
methodology for accomplishing the stated goals of the program.
Page 4 of 4
RESOURCE E: CFDA (ASSISTANCE LISTING) NOTICE AND NOFO FOR URBAN INDIAN HEALTH
SERVICES
Fish & Wildlife
Service Risk
Assessment
RESOURCE F
FISH & WILDLIFE SERVICE RISK
ASSESSMENT
U.S. Fish and Wildlife Service
Financial Assistance Recipient Risk Assessment
Date Completed: FY:

Recipient Name:
Recipient Type (select from drop down): Recipient DUNS:
Completed By-Name:
Completed By-Program: Region:
Instructions:
1. Read the "Recipient Risk Assessment Guidance" posted on the Intranet at https://inside.fws.gov/go/post/FAPO-NewAwards.
2. Complete this form once a Fiscal Year (FY) for each recipient who will be awarded one or more grant or cooperative agreement awards
from the program in the open FY. The results of this risk assessment will apply to all awards to the recipient in the open FY.
3. For each category below, enter a numerical rating of 0=Not applicable (N/A), 1=Low, 2=Medium or 3=High in the Rating box. Use the
information provided under the Rating Description sections to assist you in assigning a rating to each category. If not a new recipient,
consider the recipient's performance on all currently open and recently closed awards, when applicable to the risk category.
4. For each category below, specify in the "Basis for Rating and Other Comments" field the factors that contributed to the rating entered.
Provide enough detail to give an independent reviewer a clear understanding of the rationale used to determine the rating. If documents
exist to support your rating (e.g., performance report on previous award) identify the document(s) and specify the location of the
document(s). Here is an example of the type of detail to be entered in the "Basis for Rating and Other Comments" fields:
Category 1 Rating = 1; "Basis for Rating and Other Comments" field reads: The recipient has successfully implemented awards
under our program in the past. Some projects include sub-recipients and construction, but awards with these complexities have
been well managed. Summaries of past project results are available in our program database.
Category 1: POTENTIAL FOR IMPLEMENTATION PROBLEMS Rating:

Category 1 Rating Descriptions
0=N/A: Not a valid response.
1=Low: Project has no identifiable challenges; no past issues; typical project period for the program or project type; well-qualified recipient; project not
complex; no sub-recipients; recipient has all equipment required for the performance of the project.
2=Medium: New project for recipient; one or more sub-recipients; longer than typical project period for the program or project type; unproven recipient; recipient
has had some issues with implementation on other awards; some challenges or potential challenges identified, such as recent staff turnover or
reorganization that could affect implementation; recipient does not have all equipment required for the performance of the project but, as noted in
its application package, has plans in place to obtain necessary equipment in advance of need.
3=High: Project has multiple sub-recipients; complex project; multiple partners; construction project; recipient has had significant issues with
implementation on other awards; significant challenges identified; recipient does not have all equipment required for the performance of the project
and has not secured sufficient resources to make sure lack of equipment does not significantly delay planned project activities.
Basis for Rating and Other Comments:
Category 2: FINANCIAL MANAGEMENT SYSTEM AND FUNDS MANAGEMENT RECORD Rating:

0=N/A: Recipient is a Commercial Organization, Foreign Entity, or Individual.
1=Low: Recipient has received a Federal financial assistance award in the past, has a financial management system in place that meets the applicable
funds management requirements in CFR Part , and the program has never identified any funds management issues on previous awards to
recipient.
2=Medium: Recipient has received an award in the past, has a financial system in place that meets the applicable funds management requirements in CFR
Part , but has had funds management issues on a current or previous award(s). Recipient was responsive to USFWS communications or
requests for information or action in regards to identified issues. Issues were resolved.
FWS 3-2462
Page 1 of 4 6HSWHPEHU, 201
3=High: Recipient has never received a Federal financial assistance award and does not have experience managing Federal funds, or recipient has
received an award in the past and has had significant funds management issues on a current or previous award(s), such as routinely submitting
incorrect financial reports, requesting more than immediate cash needs, major variances between budget and actual expenditures, difficulty
maintaining required matching funds, disallowed costs, among others. One or more reports of waste, fraud or abuse currently under investigation
or determined to be valid. Recipient was not responsive to USFWS communications or requests for information or action in regards to identified
issues. Issues were never resolved.
Category 3: PERFORMANCE TRACK RECORD Rating:

1=Low: Recipient met all proposed outcomes and/or deliverables on previous award(s); on schedule to meet proposed outcomes and/or deliverables on
current award(s). Recipient met most proposed outcomes and/or deliverables on previous award(s) and reason(s) for delay or non-performance
was (were) unavoidable; on schedule or only slightly delayed to meet proposed outcomes and/or deliverables on current award(s).
2=Medium: Recipient may have had issues related to compliance with award terms and conditions on current or past award(s) but recipient was responsive to
USFWS communications or requests for information or action related to the issues. Issues were resolved.
3=High: Recipient has no past or current award with the USFWS or failed to deliver proposed outcomes and/or deliverables on previous award(s); reason(s)
for delay or non-performance was (were) unavoidable; significantly behind schedule or failing to meet maintenance of effort required on current
award(s) due to failures within recipient’s control to correct. Recipient significantly failed to comply with award terms and conditions. Recipient was
not responsive to USFWS communications or requests for information or action related to the issues. Issues were never resolved.
Category 4: STAFF LEVEL AND KEY STAFF QUALIFICATIONS Rating:

0=N/A: Recipient is an Individual.
1=Low: Recipient provided information detailing the experience and qualifications of key project personnel. All personnel appear qualified to meet the
project objectives; no past issues with recipient in regards to key staff qualification. The project is fully staffed.
2=Medium: Recipient provided information detailing the experience and qualifications for some key project personnel. All of the identified personnel appear
qualified to meet the project objectives, but other key project personnel have not yet been hired.
3=High: Recipient has not yet identified/hired any key project personnel; one or more of the personnel identified do not appear qualified to meet the project
objectives; or one or more key personnel left the project and replacement(s) have not been identified.
Category 5: DELIVERY EXPERIENCE Rating:

FWS 3-2462
Page 2 of 4 6HSWHPEHU
1=Low: Recipient has delivered the funded project/program or similar projects/programs for USFWS or other Federal agencies for at least five years.
2=Medium: Recipient has delivered the funded project/program or similar projects/programs for USFWS or other Federal agencies for at least two years.
3=High: Recipient has never delivered the funded project/program or similar projects/programs, or has delivered the funded project/program or similar
projects/programs for USFWS or other Federal agencies for less than two years.
Category 6: AWARD ADMINISTRATION AND REPORTING COMPLIANCE Rating:

0=N/A: Recipient has no past or current award from the program.
1=Low: Recipient has been timely in the submission of budget and project amendment requests, prior approval requests, financial and performance
reporting, extensions of performance period and reporting due dates, and significant development reports, as applicable.
2=Medium: Recipient has mostly been timely in the submission of budget and project amendment requests, prior approval requests, financial and performance
reporting, extensions of performance period and reporting due dates, and significant development reports, as applicable. When out of compliance,
recipient was responsive to written notifications and requests from the USFWS regarding late or incomplete requests or reports.
3=High: Recipient has consistently been late in the submission of budget and project amendment requests, prior approval requests, financial and
performance reporting, extensions of performance period and reporting due dates, and significant development reports, as applicable. Recipient is
seldom or not at all responsive to written notifications and requests from the USFWS regarding late or incomplete requests or reports.
Category 7: SINGLE AUDIT Rating:

0=N/A: Recipient is a Commercial Organization, Foreign Entity, or Individual.
1=Low: Recipient is a government or non-profit entity and their application indicates that they were not required to submit a 6LQJOH$XGLWreport for their
most recently closed fiscal year; recipient completed D6LQJOH$udit for at least one of their two most recently closed fiscal years. Recipient
submitted required 6LQJOH$XGLWreport to the Single Audit Clearinghouse on time. Recipient did not have any Qualified or Adverse/Disclaimer
opinions, significant internal control deficiencies or findings for non-compliance.
2=Medium: Recipient has not had any Adverse/Disclaimer opinions, more than two significant internal control deficiencies, or more than two findings for non-
compliance on DQ\6LQJOH$udit conducted in the last five years. Recipient was late in submitting required 6LQJOH$XGLWreport to the Single Audit
Clearinghouse.
3=High: Recipient has had an Adverse/Disclaimer opinion, more than two significant internal control deficiencies, or more than two findings for non-
compliances on DQ\6LQJOH$udit conducted in the last five years. Recipient has a history of not submitting 6LQJOH$XGLWreports to the Single
Audit Clearinghouse on time. Recipient currently working under a6LQJOH$XGLWCorrective Action Plan related to a current or previous award
funded by the program.
FWS 3-2462
Category 8: OTHER AUDITS REQUIRED BY FUNDING PROGRAM LEGISLATION Rating:

0=N/A: Recipient has no past or current award from the program; or previous/current/pending award funded in full with Resource Management funds. If
previous/current/pending award funded by other types of funds, program authorizing legislation does not require recipients to conduct a formal
audit.
1=Low: Recipient has had no significant internal control deficiencies or findings for non-compliance.
2=Medium: Recipient has had less than two significant internal control deficiencies and less than two findings for non-compliance.
3=High: Recipient has had more than two significant internal control deficiencies and more than two findings for non-compliance.
RISK RATING AVERAGE (auto-calculated based on numerical scores entered in Rating boxes above): 0.00
Instructions: In the Preliminary Risk Level box below, enter the preliminary risk level that corresponds with the risk rating average calculated
above, as follows:
Enter "Low" if the number in the Risk Rating Average box above is between 0-1.49
Enter "Medium" if between 1.5-2.49
Enter "High" if between 2.5-3
PRELIMINARY RISK LEVEL (Low, Medium or High):
OTHER FACTORS IMPACTING RISK LEVEL:

Instructions: Consider if there are any other factors that impact, either by raising or lowering, the recipient's preliminary risk level. If there
are such factors, describe each factor and explain how each raised or lowered the preliminary risk level in the text box below, and then enter
either "Low", "Medium" or "High" in the Final Risk Level box below.
If no such factors exist, enter "No other factors impact the preliminary risk level" in the text box below, and then enter the same value as
entered in the Preliminary Risk Level box above in the Final Risk Level box below.
FINAL RISK LEVEL (Low, Medium or High):
Instructions: Based on the result of this risk assessment, incorporate the required monitoring activities into all notices of award to the
recipient in the open FY following the "Recipient Risk Assessment Guidance" posted on the Intranet at
https://inside.fws.gov/go/post/FAPO-NewAwards.
FWS 3-2462
Sample Non-federal
Entity Policies
RESOURCE G
SAMPLE NON-FEDERAL ENTITY
POLICIES
Sample Procurement Policy G-2
Sample Subrecipient Monitoring Policy G-7

PROCUREMENT POLICY
Policy Number: 317 Last Revision: July 1, 2011
Effective: July 1, 2003 Last Reviewed: June 4, 2013

Purpose
The purpose of this policy is to establish policy for the procuring of goods and services under federal awards.

Overview
This policy implements the procurement requirements established in 2 CFR 215 – Uniform Administrative Requirements
for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non‐Profit Organizations (OMB
Circular A‐110).

Responsibility
The program director is responsible for determining whether a purchase is allowable under the terms of the federal
award and will ensure purchases are in accordance with this policy. The procurement administrator will provide decision
support upon request and the procurement office will serve as the final repository for purchase transaction records
under federal awards.

Code of Conduct
Procurement employees and other employees of Healthy and Happy Homes (HHH) engaged in procurement are
required to prevent conflicts of interest and avoid circumstances that pertain thereto. Employees are expected to be
principled in their business interactions and act in good faith with individuals both inside and outside HHH.

Any circumstance that could cast doubt or the appearance of doubt on a procurement employee’s ability to act with
total objectivity with regard to the interests of HHH is considered a potential conflict of interest. Procurement
employees are required to avoid such circumstances and prevent conflicts of interest.

The code of conduct shall govern the performance, behavior, and actions of HHH, including Board members, employees,
directors, volunteers or agents who are engaged in any aspect of procurement.
1. No employee or volunteer of HHH shall participate in the selection, award, or administration of a bid or contract
supported by federal funds if a conflict is real or apparent to a reasonable person.
2. HHH employees and members of their family shall not accept gifts, gratuities, entertainment, travel, or anything
having a monetary value in excess of $100 from a supplier or potential supplier.
3. Procurement employees or members of their family may not act as director, officer, partner, employee, agent,
or consultant with or without compensation for a current or proposed supplier or customer.

Procurement Procedures
All procurement transactions must be conducted in a manner to provide, to the maximum extent practical, open and
free competition. Buyers shall avoid purchasing unnecessary items. All contractor bids and quotations must be evaluated
1

on the basis of product quality, technical compliance with specifications, total cost, and the contractor’s acceptance of
terms and conditions of the contract.

 General procurement procedures
o Buyers must review the federal award to ensure that the goods or services to be purchased or
contracted are allowable.
o Buyers must review the federal award to verify there are no additional procurement conditions, specific
to the award, that supersede HHH’s policies and procedures.
o Determine the appropriate instrument of either a subaward or contract. A subrecipient performs a
portion of the scope of work and a contractor is a dealer, distributor, or other seller that provides foods
or services.
o Determine the price of the procurement. A purchase may not be split into multiple smaller purchases in
order to avoid the approval/documentation process.
o Positive efforts should be made to utilize small businesses, veteran‐owned businesses, women‐owned
businesses, or minority‐owned businesses.
o All correspondence with contractors must be included in the federal award file.
o Before the contract is made, the buyer must verify the contractor’s eligibility to receive federal funds
through the Excluded Parties List System (EPLS).

 For purchases under $3,000
o Formal documentation of contractor selection is not required.
o Buyers are expected to conduct an informal cost/price analysis and select the vendor offering the best
mix of quality, service, and price for the specific need.

 For purchases from $3,000 to $100,000
o The contractor selection process for goods and services of $3,000 and up to the small purchase
threshold established at 41 U.S.C. 403 (11), currently $100,000, requires three competitive written
quotes be obtained.
o Each contractor must be provided with the same description of the specifications and technical
requirements for the item or service.
o Web price lists and catalogue listings can be considered an acceptable form of bid.
o Buyers must complete a Contractor Selection Form.
o A copy of the completed Contractor Selection Form must be submitted to the Procurement Office for
payment.
o When lease option is available, an analysis of the lease versus buy option must be performed to
determine which alternative would be the most economical and practical form of procurement.

 For purchase greater than $100,000
o A Request for Proposal (RFP) must be prepared.
o A minimum of three written bids are required.
o Each contractor must be provided with the same description of the specifications and technical
requirements for the item or service.
o Written bids may be received by mail, fax, or email and must be signed by an authorized representative
of the contractor.
2

o Buyers must complete a Contractor Selection Form.
o A copy of the completed form and all written bids must be attached to the selected contractor’s invoice
and submitted to the Procurement Office for payment.
o A price, cost, or proposal analysis must be completed.
Competition
 A Request for Proposal (RFP) must provide:
o Statement of purposed that describes the extent of products and services to be provided.
o Scope of work that enumerates the specific duties to be performed by the provider and the expected
outcomes.
o Outcome and performance standards expected from the contractor and methods for monitoring
performance.
o A description of the specifications and technical requirements for the item or service, along with the
delivery schedule.
o The length, start date, and end date of the contract.
o The terms of payments for adequate performance.
o Contracting forms, certifications, and assurances.
o The requirements for contractors to submit a proposal.
o The evaluation and award process, including a timeline for the decision.
o Contact information, including the name, title, responsibilities, and means of contact for individuals
involved with the RFP.

 Non‐competitive contractor solicitation
o Buyers must complete Section III of the Contractor Selection Form when a noncompetitive contract is
made.
o A written justification explaining why a noncompetitive contract was made must also be attached to the
Contractor Selection Form. The justification must identify the reason for the noncompetitive contract,
supporting documentation, and a history of the award. The justification must be clearly written so that a
reasonable person will understand the reason for the noncompetitive contract.
o Buyers must obtain the procurement administrator authorization before issuing a noncompetitive
contract.

 Pre‐qualified contractor list
o A buyer may use the pre‐qualified contractor list for any dollar amount.
o An approved contractor is valid for a maximum of three years before having to recompete, as long as
the contractor remains in good standing.

For all procurements of $3,000 and greater, HHH requires documentation verifying that the purchase price is fair and
reasonable. Price analysis and cost analysis are the two techniques used to accomplish this purpose. The cost and price
analysis must be documented and attached to the Contractor Selection Form.
 Price Analysis – comparison of prices of multiple bids or information from other sources, such as established
catalog or market prices, or prices for similar past purchases.
 Cost Analysis – evaluation of the separate elements that make up a contractor’s total cost proposal or price to
determine if they are allowable, directly related to the requirement, and reasonable for the value received.
3

Procurement Records
The buyer must complete the Contractor Selection Form for all procurements over $3,000. The procurement
administrator is responsible for placing the Contractor Selection Form in the federal award file. All procurement
documents must be kept for a minimum of three years after the end of the federal award.

Contract Administration
Contract administration begins after award of the contract. The integrity of the public purchasing process demands that
goods or services be furnished, received, invoiced and paid as specified in the contract. For additional information, refer
to the Contract Administration Policy (HHH Policy 319).

Contract Provisions
All contracts awarded under a federal award must include the appropriate contract provisions contained in 2 CFR Part
215, Appendix A to Part 215 – Contract Provisions. The contract provisions include:
1. Equal Employment Opportunity—
2. Copeland “Anti‐Kickback” Act (18 U.S.C. 874 and 40 U.S.C. 276c
3. Davis‐Bacon Act, as amended (40 U.S.C. 276a to a‐7)—
4. Contract Work Hours and Safety Standards Act (40 U.S.C. 327‐333)
5. Rights to Inventions Made Under a Contract or Agreement
6. Clean Air Act (42 U.S.C. 7401 et seq.) and the Federal Water Pollution Control Act (33 U.S.C. 1251 et seq.), as
amended
7. Byrd Anti‐Lobbying Amendment (31 U.S.C. 1352)
8. Debarment and Suspension (E.O.s 12549 and 12689)

4

CONTRACTOR SELECTION FORM
Contractor Name: _____________________________________________ Date Awarded : _________
 This form must be used to document the selection of contractor for all purchases of $3,000 or more.
 Section I must always be completed in entirety.
 If choosing a pre‐qualified contractor, attach a quotation or explanation of pricing and complete Section I and signature
sections only.
 Procurements over $100,000 require a RFP and written proposals, which must be included with this form.

Section I – Basic Information.
Federal Award Name: _____________________________________
Federal Award Contact: ___________________________________
Purpose of Procurement:
__________________________________________________________________________________________________
Service or Item Description:
__________________________________________________________________________________________________
Contractor Selected: ______________________________________
Was this contractor chosen from the Pre‐Qualified Contractor List? Yes____ No ____

Section II – Competitive Selection: The buyer must receive written quotes from a minimum of three contractors. The buyer must
record each contractor and quotation below and attach copies of any RFPs and bids to this form.
Contractor: ______________________________________ Price:___________

Section III: Noncompetitive Procurement: Choose one or more reasons below and attach a written explanation supporting the
reason(s) chosen.

_____ At least three quotations/proposals were requested and only one response was received
_____ Required by the terms of the sponsor’s written solicitation or RFP – attach copy
_____ Unique or prior experience, expertise, professional stature or key personnel
_____ Proprietary item with unique requirements or “brand name” – only source capable of meeting HHH requirements
_____ Extreme Urgency – insufficient time to conduct a competitive source selection due to the extreme urgency of the
requirement (nature of urgency must be fully documented in file).

Section IV: Signatures and Authorization: Buyer is responsible for obtaining signatures.

 Buyer (required)
__________________________________ __________________________________ __________
Printed Name Signature Date

 Program Director (required)
__________________________________ __________________________________ __________

 Executive Director (required for ≥ $100,000):
__________________________________ __________________________________ __________

 Procurement Administrator (required noncompetitive contract):
__________________________________ __________________________________ __________

5

SUBRECIPIENT MONITORING POLICY
Policy Number: 879 Last Revision: July 1, 2012
Effective: July 1, 2007 Last Reviewed: February 9, 2013

Purpose
The purpose of this policy is to establish policy to monitor the programmatic, administrative, and financial activities of
subrecipients in order to ensure proper stewardship of federal funds.

Overview
This policy implements the requirements established in 2 CFR 215 – Uniform Administrative Requirements for Grants
and Agreements with Institutions of Higher Education, Hospitals, and Other Non‐Profit Organizations (OMB Circular A‐
110) and with OMB Circular A‐133, Audits of States, Local Governments, and Non‐Profit Organizations.

Responsibility
The Grants Office is responsible for implementing and executing this policy.

Applicability
This policy applies to all subawards issued under federal awards made to Health and Happy Homes (HHH). Contractor
agreements are not subject to this policy.

Procedures
I. Pre‐Award Procedures

The pre‐award/proposal stage includes all activities conducted in advance of an award. Before a subaward is issued, the
Grants Office will perform an assessment of the subrecipient entity. Risk will be determined through examination of a
number of factors, including but not limited to:
 Evidence of effective financial controls within the subrecipient’s systems
 Experience of the subrecipient’s program staff
 Prior experience with the subrecipient
 Size of the subrecipient award
 Award complexity

Based on the assessment, the subaward will be given a risk rating of low, medium, or high. The Grants Office will
develop an appropriate monitoring based on the level of risk.
 Low Risk ‐ Monitor subrecipient for compliance with programmatic and financial reporting requirements. The
subrecipient is required to submit annual performance and financial reports. The subrecipient must submit a
copy the annual A‐133 audit report to HHH, if applicable.
 Medium Risk – A sample of subrecipient invoices will be selected for further review. Subrecipients will be asked
to provide supporting documentation for all expenditures on selected invoices. The subrecipient is required to
submit progress and financial reports every six months. The subrecipient must submit a copy the annual A‐133
audit report, if applicable, to the Grants Office.
 High Risk – The subrecipient must attend a pre‐award training on financial and program requirements of federal
awards. The subrecipient will be paid on a reimbursement basis after submitting supporting documentation for
each invoice. At least annually, the Grants Office must conduct on‐site monitoring visits for high‐risk
1

subrecipients. The subrecipient must submit quarterly programmatic and financial reports. The subrecipient
must submit a copy the annual A‐133 audit report, if applicable, to the Grants Office.

II. Award Procedures

Upon receipt of the award notice, the Grants Office supplies copies of the Notice of Award (NOA), Memorandum of
Agreement, budget and scope of work to the subrecipient in a single package. The information provided to the
subrecipient includes the CFDA title and number, award name and number, award year and the name of the Federal
agency as outlined in OMB Circular A‐133. Requirements imposed on the subrecipient by Federal laws, regulations and
the provisions of the grant are communicated to the subrecipient by the information included in the Memorandum of
Agreement and NOA.

III. Post‐Award Procedures

Throughout the life of a subaward agreement, the Grants Office will work with the subrecipient to ensure that federal
awards are used for authorized purposes in compliance with laws, regulations, and the provisions of the grant
agreement. Upon identification of noncompliance, the Grants Office may revise the subrecipient’s risk level and
monitoring plan.

On an annual basis, the Grants Office will send a letter to the subrecipient requesting a copy of the subrecipient’s audit.
The letter requests a copy of the A‐133 audit for all subrecipients expending $500,000 or more in Federal awards during
the subrecipient’s fiscal year, or a financial audit/financial statements from subrecipients that are exempt from the
requirements of A‐133. Upon receiving the A‐133 audit, the audit will be reviewed for audit findings pertaining to the
HHH subaward. Based on the A‐133 audit, the Grants Office may revise the subrecipient’s risk level and monitoring plan.

2

Solutions
RESOURCE H
SOLUTIONS
ANSWERS TO EXERCISE: ADMINISTRATION OF PROPERTY TYPES
Real §200.311(a) §200.311(b) §200.311(c)

Property
The title rests with the non- To be used for the originally The non-federal entity
federal entity. authorized purpose as long as must request disposition
needed for that purpose instructions from the
awarding agency, which
may include the retention
of the title, sale of the
property, or transfer of the
title.
Equipment §200.313 (a) §200.313 (b), (c), (d) §200.313 (e)
The title rests with the non- To be used for the authorized If the value at disposition
federal entity. purposes until the grant has is less than $5,000, the
ended or until the equipment non-federal entity may do
is no longer needed for the with it as it likes with no
project, at which time the obligation to the federal
property may be used for government.
other federal projects; must
also make available to other If it is more than $5,000,
federally funded projects if it the non-federal entity must
does not interfere with the request disposition
original purpose instructions from the
agency. If the agency fails
States are to follow the state to respond in 120, the
law for use, management, equipment may be
and disposition. retained or sold. If the
equipment is sold, the
agency is entitled a
percentage of the sale.
RESOURCE H: SOLUTIONS
Supplies §200.314 (a) Not specifically addressed §200.314 (a)
The title rests with the non- If residual supplies exceed

federal entity. $5,000 in value, they
should be used on other
federally sponsored
projects. If not needed for
that purpose, the non-
federal entity may retain or
sell the supplies but must
reimburse the government
for its share.
Intangible §200.315 (a) §200.315 (a) §200.315 (a)

Property
The title rests with the non- Must be used for the original, Disposition requirements
federal entity. authorized purpose are the same for
equipment at §200.313
§200.315 (b) (e).
The government retains a
right to use and allow others
to use any copyrighted
materials developed (or for
which copyrights were
purchased) under a federal
award.
§200.315 (c)
Patents and inventions are
subject to 37 CFR 401.
§200.315 (d), (e)

The federal government has a
right to obtain, reproduce,
publish, and use data
produced under an award,
and to authorize others to do
the same. Also, research data
relating to published research
findings used by the federal
government to develop an
agency action having the
force and effect of law may be
obtained by the public through
a Freedom of Information Act
(FOIA) request.
SUGGESTED SOLUTIONS TO CAPSTONE: REVISING PROCUREMENT

POLICIES
Overview
 The policy needs to be updated to reference 2 CFR 200

 If the non-federal entity opts for the three-year grace period to implement the procurement
changes, then the policy must indicate this decision. (2 CFR 200.110(a).)
Code of Conduct
 An organizational conflict of interest would be required under 2 CFR 200.318(c)(2) if the
organization has a parent, affiliate, or subsidiary organization
 $100 is probably not a “nominal value” under 2 CFR 200.318(c)(1) and this amount should be
revised
 The code of conduct must include potential disciplinary actions for employees that violate the
conflict of interest policy
 The code of conduct should also include a prohibition on an employee having a financial interest
in a potential contracting firm
 The general procurement procedures need to incorporate how the non-federal entity will make
positive efforts to award contracts to minority businesses, women’s business enterprises, and
labor surplus area firms. A list of actions is found at 2 CFR 200.321(b).
 The policy should also note that buyers should avoid acquisition of duplicative items (2 CFR
200.318(d)), inter-entity agreements should be considered where appropriate (2 CFR
200.318(e)), and that federal excess and surplus property should be considered when feasible
(2 CFR 200.318(f))
 Reference to EPLS should be changed to the Exclusions Extract on SAM.gov and reference to
2 CFR 200.212 should be included. Additional information about printing the Exclusions Extract
information should also be included.
 2 CFR 200.318(i) requires the non-federal entity to maintain records “sufficient to detail the
history of procurement.” The non-federal entity needs to revise the policy to require purchases
under $10,000 are properly documented.
 The non-federal entity has the flexibility to increase their small purchase threshold to $250,000
 The policy should indicate that "sealed bids" is the preferred method for awarding construction
contracts
Competition
 The policy should include the list of prohibited activities that restrict competition that are
identified at 2 CFR 200.319(a).
 The policy should specifically state that providing geographic preference in awarding contracts
is prohibited under 2 CFR 200.319(b).
 The policy should include provisions to limit a detailed product specification, when possible. (2
CFR 200.319(c)(1).)
 The policies under the pre-qualified contractor list should be revised to ensure the list is current
and contains enough qualified sources. For example, the policy should indicate how contractors
are added to the list and which employee is responsible for periodically reviewing the list. (2
CFR 200.319(d).)
 The non-federal entity may wish to include information detailing how a Request for Proposal
would be advertised. (2 CFR 200.320 (d)(1).)
 The non-federal entity should include specific information about the decision making process in
awarding contracts. (2 CFR 200.320(d)(3).)
 The non-competitive contractor solicitation policy must be updated to identify the circumstances
found at 2 CFR 200.320(f).
 The Request for Proposal (RFP) provisions should also reference the bonding requirements
found at 2 CFR 200.325 for construction contracts greater than $125,000.
 2 CFR 200.323(a) requires non-federal entities “make independent estimates before receiving
bids or proposals.”
Procurement Records
 The policy should indicate how the non-federal entity will comply with a federal awarding agency
or pass-through entity review, as explained at 2 CFR 200.324.
Contract Provisions
 The contract provisions need to be updated to reflect the required provisions found in Appendix
II to 2 CFR 200.
CONTRACT PROVISIONS MATRIX

Threshold
A. Breach of Contract Simplified Acquisition Must identify sanctions and penalties

Threshold
B. Termination for Cause and $10,000 Must include basis of settlement and effects of
Convenience termination
C. Equal Employment All Construction References 41 CFR Part 60-1.3

Opportunity Contracts
D. Davis-Bacon Act $2,000 (Construction Must include Copeland "Anti-Kickback" Act

Contracts when
required by law)
E. Contract Work Hours and $100,000 (Contacts Does not apply to the purchases of supplies or
Safety Standards Act Involving Mechanics or materials ordinarily available on the open market
Laborers)
F. Rights to Inventions Made All For research and development contracts

Under Contract or Agreement
G. Clean Air Act and Federal Simplified Acquisition Should include statement that violations will be
Water Pollution Control Act Threshold reported to federal awarding agency and the
Regional Office of the Environmental Protection
Agency (EPA).

Threshold
H. Debarment and All Must ensure that no contracts are awarded to

Suspension parties listed on the Exclusions Extract on
SAM.gov.
I. Byrd Anti-Lobbying $100,000 Contracts must file a certification.

Amendment
J. Procurement of Recovered $10,000 Applicable for state and local governments. See
Materials §200.322.
Contractor Selection Form

 The form must be revised to indicate that all procurements must be documented.
 Instructions requiring the buyer to attach a printout of the Exclusions Extract search from
SAM.gov should be included.
 Section III must be revised to align with 2 CFR 200.320(f).
 At the non-federal entity’s discretion, the $100,000 threshold can be raised to $250,000.
ANSWERS TO CAPSTONE: USING THE ADMINISTRATIVE

REQUIREMENTS TO RESOLVE TERMINATION AND ENFORCEMENT
ISSUES
1. You are a federal grants official. You read an article in the newspaper that the executive
director of XYZ Nonprofit (one of your grant recipients) quit after a fight with XYZ's board of
directors and that several staff members and senior management personnel subsequently also
left. When you call XYZ, the receptionist tells you that none of the key project personnel still
work at XYZ and that the project has been put on hold indefinitely. What action should you
take?
In these circumstances, immediately withholding payment (§200.338(a)) while the matter

is investigated. Assuming that what the receptionist says is true, termination
(§200.338(c) and §200.339(a)(1)) is probably most appropriate unless the Board can
provide credible evidence that it can get the project restarted. However, given the
recipient’s lack of notification about the situation, any continued grant should be subject
to special award conditions (§200.207(a)) and close monitoring.
2. What if, in the above situation, instead of reading about it in the newspaper, you received a
letter from XYZ's board of directors informing you that all key staff had left and requesting that
XYZ be let out of its grant agreement?
Accept their termination request (you don’t have a choice per §200.339(a)(4)).
3. Big City is performing a $5 million construction project supported by your agency. The annual
audit reveals that the city failed to require its contractors to pay their employees Davis-Bacon
prevailing wage rates. What should your agency do to deal with this situation?
Disallow the costs related to Big City’s failure to comply (§200.338(b)).

4. Because of procurement irregularities, the government of Smalltown has been placed on high-
risk status with special award conditions, including payment on a reimbursement basis.
Problems continue, however, and your agency suspends its award to Smalltown on March 1
pending termination proceedings. On March 15, you receive an SF-270, requesting
reimbursement. Should you deny or approve the payment request?
If costs were properly incurred before suspension, you should approve the payment
request, for instance for contractor invoices for work completed before the suspension,
or payroll costs for February. (§200.342(a)).
ANSWERS TO COURSE CAPSTONE: FINDING ANSWERS IN THE

Scenario 1
Facts: The Department of Labor (DOL) has identified the XYZ Community Action Agency as having
an accounting system that is inadequate to identify, manage, and control its costs under their DOL
grant. As a result, DOL has established a special award condition (or “high risk” determination) that
the XYZ Agency should hire a CPA firm to establish a more acceptable accounting system. DOL
has given XYZ three months to accomplish this task.
Questions:
a. Is it within DOL’s right to do this?
Yes, as long as they follow the provisions in §200.207.
b. Does DOL have to get OMB approval to take this action?
No.
c. Who pays the costs?
The costs are allowable indirect costs.
d. What happens if XYZ refuses to cooperate?
The agency could deny funding for a renewal or continuation or even terminate the grant.
Scenario 2
Facts: The Department of Health and Human Services (HHS) wants to require Head Start grantees
to furnish reports showing costs, on a per child basis, of providing health and nutritional services to
children receiving Head Start services.
Questions:
a. Does the Uniform Guidance allow HHS to do this?
The Uniform Guidance requires this information. In §200.301, "recipients must also
provide cost information to demonstrate cost effective practices (e.g., through unit cost
data)."
b. If so, who pays the costs of establishing such a system?
If it is required under the grant, the government must pay.
Scenario 3
Facts: The University of South Central North Dakota has a grant, which requires cost sharing,
from the National Science Foundation (NSF). Dr. Jones is the university's principal investigator on
the grant. Rather than charging Dr. Jones’ salary to the grant as a direct charge, the university
intends to pay her salary from its own resources and show that payment as part of its cost share.
Questions:
a. May the university do this? Why or why not?
Yes, for the portion of her salary that benefits the grant. A recipient may contribute its
own resources as part of its cost share, so long as the contribution meets the criteria in
§200.306(b).
b. May the university include Dr. Jones’ fringe benefits as cost share?
Yes, for that portion of her fringe benefits that benefits the grant.
Scenario 4
Facts: A National Park Service (NPS) grantee has developed a brochure on how to build
environmentally safe nature trails using timber damaged during Hurricane Algernon and slag and
slurry from abandoned mines. Grant funds were used to develop the brochure and the grantee is
selling copies for $5.00 each. The grant is still active. The terms of the grant are silent as to the
disposition of the proceeds from sale of the brochures.
Questions:
a. What happens to the proceeds? Why?
The program income must be deducted from the total program allowable costs to
determine the net allowable costs. §200.307(e)(1), which requires the use of the deductive
alternative unless prior approval is given by the agency.
b. What if the grant period has expired and the grantee continues to earn proceeds?
The non-federal entity has no obligation to the government, unless an agreement was
negotitated during the closeout process. §200.307(f)
Scenario 5
Facts: The Department of Education (ED) has made a grant to the National Educational Research
System. The ED grants official is visiting the grantee but is refused access to the grantee’s
accounting records dealing with personnel costs charged to the grant.
Questions:
a. What should the grants official do?
The Department is entitled to all grants-related records, as stated in §200.336. The

Department should demand, in writing, access to the records. The Department could
temporarily withhold cash payments until access is granted, as provided for in
§200.338(a). If the recipient fails to provide the records, the Department should terminate
the award (§200.338(c)).
Presentation Slides
RESOURCE I
PRESENTATION SLIDES
Uniform Administrative Requirements for Federal
Grants: 2 CFR 200 (Subparts A through D)
Course Objectives
 Describe the history, purpose, and applicability of the Uniform

 Use 2 CFR 200, Subparts A & B, to locate information about
general terms and requirements
 Identify the pre-award requirements for federal awarding agencies
and describe how they affect non-federal entities
 Use 2 CFR 200, Subpart D, to locate needed information about
financial and program management standards
property requirements
procurement requirements
2
Course Objectives, continued

reporting requirements
subawards
 Use 2 CFR 200, Subpart D, to locate information about award
records
noncompliance and termination
 Use 2 CFR 200, Subpart D, to locate needed information
about closeout
 Apply the administrative requirements found in the Uniform
Guidance
3
1
Introduction to the Uniform
Module Objective
 Describe the history, purpose, and

applicability of the Uniform
Significance and Applicability of the Uniform

After completing this lesson, you should be

able to:
 Explain the significance of the Uniform
Administrative Requirements for grants
management and its applicability to your
awards
2
Significance of the Uniform Administrative
Requirements
Pre-Award, Post-Award, and Closeout Phases
Discussion
Poll: Do you believe the Uniform Guidance

consistently applies to all award recipients?
A.Yes
B.No
3
Discussion, continued
• Who are some of the entities who are impacted by the recent
Uniform Guidance reform?
• What are some of the primary advantages to creating uniform
requirements for all recipient entities?
• To what phases of the grants life cycle do the provisions in 2
CFR 200 refer?
• In what specific areas does the Uniform Guidance establish
requirements?
• What else does the Uniform Guidance address besides these
requirements?
10
Activity: Consequences for Uniform

Guidance Incompliance
Compliance to the Uniform Guidance is very

important, as there can be serious
consequences for businesses that do not
comply. What do you think some of these
consequences might be?
11
"Should" versus "Must"
• Uniform Guidance uses the words "should" and

"must" when identifying the responsibilities of
federal awarding agencies and non-federal
entities
• "Should" implies a suggested course of action and
generally refers to best practices
• "Must" indicates a required action. Failure to
comply with a required action may result in:
• An audit finding
• Federal awarding agency or pass-through entity
imposing special conditions on the award
• Legal consequences
12
4
History of the Uniform Administrative
Requirements
After completing this lesson, you will be able

to:
 Understand the history behind the Uniform
Guidance
13
Implementation of the Uniform Guidance
14
Consolidation of Circulars
15
5
Discussion
‖ What are your biggest concerns about the

uniform administrative requirements?
16
Structure of the Uniform Guidance

to:
 Locate information within the Uniform
Guidance
17
Structure of 2 CFR 200
18
6
Exercise: Identifying Sections in
the Uniform Guidance
Directions
1.Read each scenario listed
2.Use 2 CFR 200 (in the text, at your table, or
at https://www.ecfr.gov) to determine where
to locate the answer to each scenario
19
General Provisions of the Uniform

Guidance
20
Module Objective
 Use 2 CFR 200, Subparts A & B, to

locate information about general
terms and requirements
21
7
Acronyms and Definitions in the Uniform
Guidance

to:
 Identify and define acronyms and terms
used in the Uniform Guidance
22
Acronyms and Definitions
• Acronyms
• General information
about definitions
• Essential definitions
for grants
management
• New definitions
added to the
Uniform Guidance
23
Discussion
‖ Which acronyms are new to you?
24
8
Definitions Exclusive to the Uniform Guidance
25
Discussion
‖ Of the new definitions, which is most useful?

Do any leave room for further questions?
26
General Provisions of the Uniform Guidance

to:
 Explain the general provisions of the
Uniform Guidance
27
9
General Provisions
• Purpose and Application of the Uniform

Guidance
• Agency Implementation and Effective Date
• English Language Requirements
• Enhancing Accountability Through New
Requirements
—Conflict of Interest
—Mandatory Disclosures
28
§200.102 Exceptions
Agencies listed in bold, underlined font below have exceptions to 2

CFR 200.
29
Requirements Concerning Conflict of Interest
30
10
Discussion
‖ What is your entity's conflict of interest

policy?
31
Exercise: Reviewing a Conflict of

Interest Policy
Directions
1.Read the COI policy resource. It is also
located at
https://www.epa.gov/grants/epas-financial-
assistance-conflict-interest-policy
2.Answer the questions provided
32
Discussion
‖ What steps has your entity taken to address

the requirements under 2 CFR 200.113?
33
11
Pre-Federal Award Requirements and
Contents of Federal Awards (2 CFR
200 Subpart C)
34
Module Objective
 Identify the pre-award

requirements for federal awarding
agencies and describe how they
35
Financial, Performance, and Real Property

Reporting
36
12
Federal Award Instruments

to:
 Select the appropriate federal award
instrument
37
§200.200 Purpose of Subpart C
• Grant Agreements
• Cooperative Agreements
• Contracts
• Fixed Amount Awards
38
Cost Reimbursement Grants Versus Fixed

Amount Awards
39
13
Discussion
‖ Have you ever used or considered using a

fixed amount award?
40
Notices of Federal Financial Assistance

to:
 Describe the requirements for a Notice of
Federal Financial Assistance.
41
§200.202 Requirements to Provide Public

Notice of Federal Financial Assistance
Programs
42
14
Activity: Review the CFDA Notice
‖ Directions
‖ Review the CFDA Notice for the Urban

Indian Health Services in Resource: CFDA
Notice and NOFO for Urban Indian Health
Services to determine if each required
element is presented.
43
§200.203 Notices of Funding Opportunities and

Appendix I to 2 CFR 200
44
Notice of Funding Opportunities
• Published at https://www.grants.gov
• Appendix I of 2 CFR 200 identifies required elements
45
15
Merit Review Process

to:
 Understand the merit review process
46
§200.204 Federal Awarding Agency Review of

Merit Proposals
47
Discussion
‖ How will 2 CFR 200.204 Federal Awarding

Agency Review of Merit Proposals affect
your entity?
48
16
Pre-award Risk Assessment

to:
 Explain the pre-award risk assessment
process
49

Risk Posed by Applicants
50
Pre-Award Risk Assessment
51
17
Updating FAPIIS
52
Discussion
• What additional factors should federal

awarding agencies examine?
• How should non-federal entities prepare for a
risk assessment?
53
Application Forms

to:
 Determine which forms may be required for
award applications.
54
18
§200.206 Standard Application
Requirements
• If approved by OMB, may be required

• If not approved by OMB, may be collected
as options
55
Discussion
‖ How do you deal with gathering (as a federal

agency or pass-through entity) or providing
(as an applicant) information that does not fit
on the form?
56
Specific Conditions

to:
 Identify the requirements an agency may
place on a recipient as a result of the risk
assessment
57
19
Risk Posed by Applicants
58
§200.207 Apply Specific Conditions, As

Necessary
59
§200.207 Specific Conditions
60
20
Discussion
• How do you communicate additional

conditions with an awardee?
• If you are an awardee, do you ask for
technical assistance?
61
Certifications and Representations

to:
 Describe the purpose and use of
certifications and representations
62
§200.208 Certifications and Representations
63
21
Discussion
‖ What consequences have you seen

agencies apply related to certifications and
representations?
64
Federal Award Document

to:
 Identify and explain the required elements
of a federal award document.
65
§200.210 Information Contained in a Federal

Award
66
22
Discussion
Poll: What provision in 2 CFR 200 is designed to ensure that non-

federal entities are using federal funds efficiently and effectively?
A. Requirement for federal agencies to develop performance goals
to measure project performance.
B. Requirement for uniform set of data elements in grant awards.
C. Requirement for federal agencies to assign a Federal Award
67
Discussion
Poll: What provision in 2 CFR 200 is intended to enhance data

quality by allowing the public to more easily track specific
government awards and spending?
68
Discussion
Poll: What provision in 2 CFR 200 is designed to improve the

ability of non-federal recipients to understand and manage grant
awards?
69
23
Information that Becomes Public

to:
 Identify the information about an award that
becomes public
70
Public Information (§200.211; §200.212;

§200.213)
• §200.211 Public access to federal award

information
• §200.212 Reporting a determination that a non-
federal entity is not qualified for a federal award
• §200.213 Suspension and debarment
71
Discussion
‖ What do you need to be cognizant of, given

that this information will be made public?
72
24

to:
 Identify available options to remedy
noncompliance
73
§200.338 Remedies for Noncompliance
74
Discussion
• What types of noncompliance issues have you

encountered and how were they resolved?
• Under which circumstances might a federal
agency or pass-through entity apply a remedy of
noncompliance instead of a specific condition?
75
25
Financial and Program
Management Standards
76
Module Objective
 Use 2 CFR 200, Subpart D, to locate

needed information about financial
and program management standards
77
Standards for Financial and Program

Management
• Statutory and national policy requirements

• Performance measures
• Financial management
• Internal controls
• Bonds
• Payment
• Cost sharing or matching
• Revision of budget and program plans
• Period of performance
78
26
Activity: Financial and Program Management
Directions
Answer the following questions by reviewing §§200.300 to 200.309 in
the text, at your table, or at https://www.ecfr.gov. Identify the correct
citation that relates to each question.
1. Do your entity's policies reference the required whistleblower
protections? For federal agencies and pass-through entities: How
will you verify recipient compliance?
2. Does your entity identify the Assistance Listings (formerly known as
CFDA) number and FAIN on all awards?
3. Does your entity use the "Green Book" or COSO's Integrated
Framework as a resource?
4. Does your entity earn more than $500 in interest on federal awards
a year?
5. Does the prohibition of voluntary committed cost sharing affect your
entity?
6. In your experience, do federal agencies typically respond within 30
days to a budget revision request?
7. Do your internal policies conform with the definition for "period of
performance"?
79
Statutory and National Policy Requirements

to:
 Explain how statutory and national policy
requirements affect grants management
80
Overview of Financial and Program

Management
• Statutory and National Policy Requirements

• Performance Measures
• Internal Controls
• Financial Management
• Cost Share / Matching
• Program Income
• Revision of Budget and Program Plans
81
27
§200.300 Statutory and National Policy
Requirements
82
Discussion
‖ How does your entity identify applicable

statutory and national policy requirements?
83
Performance Measurement

to:
 Explain how the Uniform Guidance
expands the use of performance measures
in grants administration
84
28
Performance Measurement Life Cycle
85
§200.301 Performance Measurement
Non-federal entities must:

• Relate financial data to performance
• Show cost effective data
• Measure performance
Federal awarding agencies must:
• Communicate expectations
• Provide clear goals
• Analyze and apply data
86
Discussion
‖ How does your organization comply with the

performance measurement requirements?
87
29
Financial Management

to:
 Identify the necessary components of a
compliant financial management system
88
§200.302 Financial Management
89
Discussion
Poll: My financial management system is

equipped today to ensure compliance with 2 CFR
200.302 Financial management. Do you agree or
disagree with this statement?
A.Agree
B.Disagree
90
30
Of the requirements listed in §200.302 (b),

which do you believe is most critical and why?
91
Internal Controls

to:
 List internal controls that use best practices
92
§200.303 Internal Controls
93
31
Discussion
Poll: Are you familiar with the COSO Internal

Control – Integrated Framework?
A.Yes
B.No
94
Poll: Does your entity use the COSO Internal

Control – Integrated Framework when
evaluating your internal controls?
A.Yes
B.No
95
Bonds, Payment, Cost Sharing or Matching,

and Program Income

to:
 Explain payment procedures for federal
awards, and comply with bonding, cost
sharing, matching, and program income
requirements.
96
32
§200.304 Bonds
97
§200.305 Payment
98
Discussion
• What policies does your entity have

regarding grant payments?
• How could those policies be improved?
99
33
§200.306 Cost Sharing or Matching
• Basic Rule Definition

• Criteria for Acceptance of Contributions
• Valuation of Donated Services
—Volunteer services
—Employees of other organizations
• Valuation of Third-Party Donated Supplies,
and Loaned Equipment, and Services
• Valuation of Third-Party Donated Equipment,
Buildings, or Land
100
§200.307 Program Income
• General Standard
• Use of Program Income
—Additive Alternative
—Matching Alternative
—Deductive Alternative
• Program Income After the Award Period
• Cost of Generating Program Income
101
§200.307 Program Income, continued
102
34
Discussion
• What policies does your entity have

regarding program income?
• What internal controls do you have to
support these policies?
103
Revision of Budget and Program Plans and

Period of Performance

to:
 Identify situations that require agency prior
approval
104
§200.308 Revision of Budget and Program

Plans
Revisions requiring prior
approval:
• Change in Scope
• Change in Key Personnel
• Project Disengagement
• Costs that Require Prior
Approval
• Transfer of Funds for
Participant Support
• Contracting /
Subawarding
• Changes to Cost-Share
• Additional federal funds
105
35
Discussion
• Discuss your experiences in obtaining or granting prior approval

• Poll: Has your entity ever granted, or requested, a no-cost extension?
A. Yes
B. No
• Poll: Have you experienced a situation in which a recipient has tried to
initiate a one-time extension to the period of performance merely for
the purpose of using unobligated balances (which goes against 2 CFR
200.308)?
A. Yes
B. No
106
Poll: Have you experienced a situation in which a

recipient has tried to initiate a one-time extension to
the period of performance merely for the purpose of
using unobligated balances (which goes against 2
CFR 200.308)?
A.Yes
B.No
107
§200.309 Period of Performance
108
36
Module Capstone: Reviewing a Financial
System Against the Administrative
Requirements Objective
This capstone will allow you to do the

following:
 Practice using 2 CFR 200, Subpart D, to
locate needed information about financial
and program management standards
109
Module Capstone: Reviewing a Financial

System Against the Administrative
Requirements
Directions
Read the excerpts from the policy manual,

then work as a group to determine the entity's
compliance with 2 CFR 200
110
Property Standards
111
37
Module Objective
 Use 2 CFR 200, Subpart D, to

locate needed information about
property requirements
112
Property Standards
• Insurance coverage
• Real property
• Federal-owned and exempt property
• Equipment
• Supplies
• Intangible property
• Property trust relationship
113
Activity: Property Standards
Directions
Answer the following questions by reviewing the Uniform

Guidance in Resource, 2 CFR 200: Uniform Guidance - Uniform
Administrative Requirements, Cost Principles, and Audit
Requirements. Identify the correct citation that relates to each
question.
1. Does your entity currently submit an annual inventory report
for federally-owned property?
2. Does your entity currently identify the FAIN for each piece of
property acquired or improved with federal funds?
3. Does your entity currently hold all property acquired or
improved with federal funds in a trust?
114
38
Property Definitions

to:
 Apply the appropriate definitions to property
items
115
Categories of Property
116
Property as Defined in the Uniform

Guidance
• Computing devices
• Equipment
• General purpose equipment
• Information technology systems
• Personal property
• Property
• Real property
• Special purpose equipment
• Supplies
117
39
Exercise: Applying Property
Definitions
Directions
For each group, select the correct term that

identities the type of property for the item
118
Property Management Standards

to:
 Identify standards for title, use, disposition,
and insurance coverage of real and
intangible property, equipment, and
supplies
119
Property Management Standards
• Insurance coverage
• Real property
• Federally-owned and exempt property
• Equipment
• Supplies
• Property trust relationships
120
40
Discussion
‖ What types of properties have you had to

manage personally on your federal grant
awards?
121
Equipment Disposition
122
Discussion
‖ How do you ensure the FAIN is associated

with each piece of property acquired under
federal awards?
123
41
Exercise: Administration of
Property Types
Directions
1. Summarize the treatment of each property
type
2. Include the appropriate citations
124
Procurement Standards
125
Module Objective

procurement requirements
126
42
Procurement Standards
• Procurements by States
• Competition
• Methods of Procurement
• Contracting with Small and Minority
Businesses
• Contract Provisions
127
Procurements by States

to:
 Explain the procurement policies that states
must follow
128
Discussion

• How many of you work with state
requirements for procurement today?
• How many of you have worked with state
requirements for procurement in the past?
129
43
§200.317 Procurements by States
130
Procurements by Others

to:
 Explain the procurement policies that all
entities, except states, must follow
131
Discussion

• How many of you work with non-state entity
requirements for procurement today?
• How many of you have worked with non-state
entity requirements for procurement in the past?
132
44
§200.318 General Procurement Standards
133
§200.319 Competition
134
§200.320 Methods of Procurement to be

Followed
135
45
§200.321 Contracting with Small and Minority
Businesses, Women's Business Enterprises,
and Labor Surplus Area Firms
136
§200.322 Procurement of Recovered Materials
137
§200.323 Contract Cost and Price
Price Analysis Cost Analysis

• Examines the total price under • Breaks down total price into
consideration as the single pricing individual cost elements (e.g.,
factor labor, equipment, material)
• Compares the total price to • Reviews and evaluates each
comparable measures/units individual element
• Used to determine that the overall • Performed only when justified by
price is reasonable the nature of the situation and/or
significant dollar values
138
46
Contract Provisions

to:
 Identify applicable contract provisions
139
§200.326 Contract Provisions and

Appendix II to 2 CFR 200
• Appendix II to 2 CFR 200

• 10 Contract Provisions
—Vary by Contract Amount and Type
140
Module Capstone: Revising Procurement

Policies

following:
 Practice assessing procurement policies for
compliance with procurement requirements
141
47
Module Capstone: Revising
Directions
Review the procurement policy found in the resource,

Sample Non-federal Entity Policies, and compare the
sample procurement policy to the requirements found in
2 CFR 200.318 to 200.326. Determine how the sample
procurement policy must be revised to be in compliance
with 2 CFR 200.
142
Performance and Financial Monitoring

and Reporting (2 CFR 200, Subpart D -
Subtitle IV)
143
Module Objective

reporting requirements
144
48
Financial, Performance, and Real Property
Reporting
145
Financial Reporting
After completing this lesson, you should be

able to:
 Identify the requirements for financial
reporting
146
§200.327 Financial Reporting
147
49
Discussion
As noted, financial information must be collected with the frequency

required by the terms and conditions of the federal award, but no less
frequently than annually nor more frequently than quarterly except in
unusual circumstances.
• Poll: Have you encountered projects with grant awards where more
frequent reporting was deemed necessary?
A. Yes
B. No
• If so, what were the reasons for the increased reporting?
148
Program Performance Reporting

to:
 Identify the requirements for performance
reporting
149
§200.328 Monitoring and Reporting Program

Performance
150
50
Discussion
‖ How has the increased emphasis on

performance measurement and reporting on
outcomes affected your entity?
151
Real Property Reporting

to:
 Discuss the provisions regarding real
property reporting
152
§200.329 Reporting on Real Property
153
51
Discussion
• Poll: How many of you have personally handled or were

involved in situations when the non-federal entity used,
acquired, or improved (under a federal award) real
property where the Federal government retained an
interest in that property for a period of 15 years or longer?
• Note that this would require more frequent reporting than
simply annual reporting
154
Subrecipient Monitoring and

Management
155
Module Objective

subawards
156
52
Subrecipient Monitoring and Management
• Subrecipient and contractor determinations

• Requirements for pass-through entities
• Fixed amount subawards
157
Subrecipient and Contractor Determinations

to:
 Differentiate between the terms
"subrecipient" and "contractor"
158
Discussion
‖ What challenges have you faced when

making the distinction between a
subrecipient and a contractor?
159
53
Requirements for Pass-through Entities

to:
 Identify the requirements for pass-through
entities
160
§200.331 Requirements for Pass-Through

Entities
• Issue proper subaward

documentation
• Conduct risk
assessment and apply
necessary special
conditions
• Conduct monitoring
and review reports
• Ensure subrecipient
compliance
• Maintain accurate files
161
IDC Decision Tree for Pass-Through Entities
162
54
Discussion
• Of the various pass-through entity requirements

regarding federal awards and sub-awards, what
would you consider to be the most important and
why?
• In your own experience, which pass-through entity
requirement have you found to be the biggest
challenge for entities?
163
§200.332 Fixed Amount Subawards
164
Record Retention and Access
165
55
Module Objective

locate information about award
records
166
Record Retention and Access
• Records retention requirements

• Requests for transfer of records
• Methods for collection, transmission, and
storage of information
• Access to records
• Restrictions on public access to records
167
Retention Requirements for Records

to:
 Discuss the record retention requirements
168
56
§200.333 Retention Requirements for
Records
• All recipient records must be kept for three

years from date of submission of final
expenditure report
• Exceptions are provided in the Uniform
Guidance at §200.333
169
Discussion
‖ §200.333 Retention Requirements for Records

addresses several exceptions that would
lengthen the standard three-year time period
required for records retention by the non-federal
entity. What are some of these exceptions?
170
Transfer and Storage Requirements for

Records

to:
 Explain the provisions regarding
transferring, collecting, storing, and
transmitting records.
171
57
Transfer and Storage
172
Discussion
‖ When would the federal awarding agency

request transfer of certain records to its
custody from the non-federal entity?
173
174
58
Module Objective

175
Recipient Noncompliance
• Remedies for noncompliance

• Termination of an award
• Notifying recipients of award termination
• Recipient opportunities to object, hearings,
and appeals
• Effects of suspension and termination
176
Informal and Formal Corrective Actions for

Insufficient Performance
177
59
Termination Process

to:
 Explain the process to terminate a federal
award
178
Termination Conditions, Requirements, and

Responsibilities
179
§200.339 Termination
• For noncompliance
• For cause
• Mutual consent
• Written notification
180
60
Discussion
How might this termination letter in FAPIIS

affect future award decisions?
181
Module Capstone: Using the Administrative

Requirements to Resolve Termination and
Enforcement Issues Objective

following:
 Practice using 2 CFR 200, Subpart D, to
182
Module Capstone: Using the

Administrative Requirements to
Resolve Termination and Enforcement
Issues
Directions
Work as a team to apply the termination

provisions found in the Uniform Guidance.
1.Answer the following questions.
2.Include citations for your answers.
183
61
Closeout Requirements
184
Module Objective

closeout
185
Award Closeout
• Closeout procedures
• Post-closeout
adjustments and
continuing
responsibilities
• Collection of amounts
due
186
62
Closeout Process

to:
 Explain the closeout process
187
§200.343 Closeout
188
Discussion
‖ What are the challenges to closing out a

grant within one year of accepting final
reports?
189
63
Post-Closeout Requirements

to:
 Discuss the agency and recipient
responsibilities after closeout
190
Post Closeout Adjustments and Continuing

Responsibilities
191
§200.344 Post-Closeout Adjustments
• Disallow costs
• Meet financial obligations
• Audit requirements
• Property management
• Record retention
192
64
Discussion
Poll: All of the following items are unaffected by the closeout of

grants except:
A. The right of an agency to disallow costs.
B. Audit requirements identified in Subpart F.
C. Record retention requirements.
D. The obligation of the recipient to return funds.
E. Property management and disposition requirements.
F. None of the above.
193
Course Capstone: Finding Answers in

the Administrative Requirements
194
Module Objective
 Apply the administrative requirements

found in the Uniform Guidance
195
65
Course Capstone: Finding Answers in
the Administrative Requirements
Directions
‖ Research each scenario assigned to your

group, identify the proper citation, and be
prepared to present your answers
196
66
RESOURCE I: PRESENTATION SLIDES
Bibliography
BIBLIOGRAPHY
NIH Ethics Program, National Institutes of Health. “Conflicts of Interest.” Feb 19, 2013. Web. March
14, 2016. <https://ethics.od.nih.gov/topics/coi.htm>
Office of Justice Programs, U.S. Department of Justice. “Conflicts of Interest.” Web. March 14,
2016. < http://ojp.gov/archives/financial_guides/financialguide09/part1/part1chap3.htm>
U.S. Department of Health and Human Services Departmental Grant Appeals Board, National
Health Plan, Inc., DAB No. 871 (1987),
<https://www.hhs.gov/sites/default/files/static/dab/decisions/board-decisions/1987/dab871.html>
United States Agency of International Development, Standard Provisions for U.S. Nongovernmental
Organizations https://www.usaid.gov/sites/default/files/documents/1868/303maa.pdf
United States Government of Commerce. Grants Policy. Last modified February 9, 2018,
http://www.osec.doc.gov/oam/grants_management/policy/

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PARTICIPANT GUIDE

Printed in the United States of America.

© Management Concepts. See inside front cover for additional details. 3

2.1.5 §200.104 Supersession ....................................................................................62

4 © Management Concepts. See inside front cover for additional details.

Lesson 10: Remedies for Noncompliance ............................................................................ 139

© Management Concepts. See inside front cover for additional details. 5

6 © Management Concepts. See inside front cover for additional details.

2.3 §200.336 Access to Records ............................................................................... 297

© Management Concepts. See inside front cover for additional details. 7

Answers to Course Capstone: Finding Answers in the Administrative Requirements ......444

8 © Management Concepts. See inside front cover for additional details.

Who Takes This Course

 Use 2 CFR 200, Subpart D, to locate needed information about subawards

 Use 2 CFR 200, Subpart D, to locate information about award records

© Management Concepts. See inside front cover for additional details. 11

 Use 2 CFR 200, Subpart D, to locate needed information about closeout

 Apply the administrative requirements found in the Uniform Guidance

Course Delivery Guide Icons

12 © Management Concepts. See inside front cover for additional details.

Morning Introductions and Course Administration

Module 1: Introduction to the Uniform Administrative Requirements

Module 2: General Provisions of the Uniform Guidance (2 CFR 200 Subparts A

Module 3: Pre-Federal Award Requirements and Contents of Federal Awards (2

Afternoon Module 3: Pre-Federal Award Requirements and Contents of Federal Awards (2

Module 4: Financial and Program Management Standards (2 CFR 200, Subpart

Module 5: Property Standards (2 CFR 200, Subpart D - Subtitle II)

© Management Concepts. See inside front cover for additional details. 13

Module 6: Procurement Standards (2 CFR 200, Subpart D - Subtitle III)

Module 7: Performance and Financial Monitoring and Reporting (2 CFR 200,

Module 8: Subrecipient Monitoring and Management (2 CFR 200, Subpart D -

Module 9: Record Retention and Access

Module 11: Closeout Requirements (2 CFR 200, Subpart D - Subtitles VIII-X)

Module 12: Course Capstone: Finding Answers in the Administrative

Requirements for Successful Completion

14 © Management Concepts. See inside front cover for additional details.

For additional information about credits and certifications

© Management Concepts. See inside front cover for additional details. 15

16 © Management Concepts. See inside front cover for additional details.

INTRODUCTION TO THE UNIFORM

2. History of the Uniform Administrative Requirements

3. Structure of the Uniform Guidance

© Management Concepts. See inside front cover for additional details. 19

20 © Management Concepts. See inside front cover for additional details.

1.1 SIGNIFICANCE OF THE UNIFORM ADMINISTRATIVE

© Management Concepts. See inside front cover for additional details. 21

referred to as the "Supercircular" or "OmniCircular." It is the culmination of years of collaboration

On June 15, 2017, through Memorandum M-17-26, the Office of

22 © Management Concepts. See inside front cover for additional details.

Grants Life Cycle: Pre-Award, Post-Award, and Closeout Phases

© Management Concepts. See inside front cover for additional details. 23

 Who are some of the entities impacted by the Uniform

1.2 THE IMPORTANCE OF COMPLIANCE

24 © Management Concepts. See inside front cover for additional details.

Example: Sample Disallowance for Failure to Follow

National Health Plan, Inc. (NHP), a nonprofit organization,

Activity: Consequences for Uniform Guidance Incompliance

Compliance to the Uniform Guidance is very important, as there

1.3 "SHOULD" VERSUS "MUST"

© Management Concepts. See inside front cover for additional details. 25

26 © Management Concepts. See inside front cover for additional details.

2.1 IMPLEMENTATION OF THE UNIFORM GUIDANCE

Timeline of the Uniform Guidance Implementation