The Office of Management and Budget (OMB) has issued the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (2 CFR Part 200), referred to as the Uniform Guidance. The new guidance consolidates, streamlines and supersedes eight existing OMB Circulars, including Circulars A-21, A-110 and A-133. The Uniform Guidance applies to new awards and existing awards receiving incremental funding on or after December 26, 2014 as determined by Federal funding agencies. This webpage will provide information on the Uniform Guidance implementation and will be regularly updated as new information becomes available.
Navigating the Uniform Guidance
For ease of navigation, the Uniform Guidance is broken down into its following subparts:
- Subpart A (200.0 - 200.99) - Acronyms and Definitions
- Subpart B (200.100 - 200.113) - General Provisions
- Subpart C (200.200 - 200.211) - Pre Award Requirements
- Subpart D (200.300 - 200.345) - Post Award Requirements
- Subpart E (200.400 - 200.475) - Cost Principles
- Subpart F (200.500 - 200.521) - Audit Requirements (includes Appendices I-XI
The procurement standards in Subpart D will become effective at Indiana University on July 1, 2016. An official statement regarding Indiana University’s adoption of the procurement standards is presented on the Office of Procurement Services website.
Subpart F will apply to audits at Indiana University beginning with FY2016.
Uniform Guidance Applicability and Federal Agency Implementation
- The applicability of the Uniform Guidance to various Federal funding mechanisms is specified in Section 2 CFR Part 200.101.
- A summary table indicating the applicability the Uniform Guidance to various Federal funding mechanisms is available. See the Applicability Table to different types of Federal awards
- Federal funding agencies are allowed a degree of flexibility in the implementation of the Uniform Guidance. For a summary of the currently known agency implementation plans, see the Federal Funding Agencies Implementation of Uniform Guidance
- NIH – Summary of actions approvable under Recipient Authorities and those requiring prior NIH approval.
NIH Recipient Authorities – Pre Approvals
- NSF – Summary of actions requiring NSF notification and those requiring prior NSF approval.
NSF Recipient Authorities – Prior Approvals
University Policies related to the Uniform Guidance
Office of Research Administration Presentations
Research Administrators Team Meetings – December 2014
Research Administrators Team Meetings – February 2015
Communications & Resources from Federal Agencies
Federal Agency Policy Guides
- All Federal Agencies - Interim Final Rule
Federal Awarding Agency Regulatory Implementation of OMB's Uniform Guidance Requirements, posted 12/19/14 in the Federal Register
- ED - Department of Education – Questions and Answers Regarding 2 CFR Part 200 - effective 12/26/14
- NIH - Grants Policy Statement - effective 12/26/14
- NIH - NIH – Uniform Guidance and Grant General Conditions FAQs - effective 12/24/14
- NSF - Grant General Conditions (GC-1) - effective 12/26/14
- NSF - Cooperative Agreement Financial & Administrative Terms & Conditions (CA-FATC) - effective 12/26/14
- NSF - Proposal & Award Policies & Procedures Guide (PAPPG) (NSF 15-1) - effective 12/26/14
- NSF - Significant Changes and Clarifications to the PAPPG
- NSF - FAQs on the National Science Foundation’s Implementation of 2 CFR § 200
Presentations & Training Materials from Non-Federal Organizations
- The Uniform Guidance: Key Issues for Universities - NCURA Webinar Slides 5/14/14
- Presentations from Council on Governmental Relations (COGR) March 5, 2015 Meeting
Costing policies perspective on the Uniform Guidance:
- F&A and the Uniform Guidance - Lynn McGinley, University of Maryland
- Uniform Guidance – F&A Pools - Mike LeGrand, University of California, Davis
- UG, Compensation – Personal Services - Naomi Schrag, Columbia University & Joe Gindhart. Washington University
Federal Panel: Challenges, Opportunities and Implementation of Uniform Guidance
- NIH Implementation of Uniform Guidance - Michelle Bulls, NIH
- NSF: Challenges, Opportunities and Implementation of UG - Jean Feldman, NSF
- USDA – NIFA’s Challenge - Cynthia Montgomery, USDA
- Federal contracts, as opposed to Federal grants and cooperative agreements, are subject to the Federal Acquisition Regulation (FAR), in addition to parts of the Uniform Guidance. See the section above entitled Uniform Guidance Applicability and Implementation to determine the applicability of the Uniform Guidance to a contracting mechanism. Links to the FAR provided here as a reference:
- OMB Circulars in effect for awards received prior to 12/26/2014 until new incremental funding is received on or after 12/26/14. See the Uniform Guidance Applicability and Implementation section above for guidance on the applicability of these circulars: