New Uniform Guidance for CNCS Grants
Dear CNCS Grant Recipients and Other Stakeholders:
As you know, the new Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards (Uniform Guidance, now consolidated in 2 CFR Parts 200 and 2205) apply to CNCS grants awarded in fiscal year 2015.
You should review the Uniform Guidance carefully. It is your
responsibility as a recipient or subrecipient of Federal funds to understand
and follow all requirements for your Federal award, including the laws and
regulations that govern the award referenced in the Terms and Conditions of
your grant award. Again, we recommend that you take advantage of existing
training and reference materials available on the Uniform Guidance, such as those
available here. In particular, the preamble to the
Uniform Guidance provides a good overview of the changes.
After you have become familiar with the Uniform Guidance, your
grants officer is your first resource for your CNCS-specific questions.
The following highlights some, but not all, of the important
changes from past OMB Circulars. This list is not exhaustive and is not a
substitute for reading and understanding the Uniform Guidance.
* §200.112.
Conflict of Interest. Requires non-federal entities (recipients and
subrecipients) to disclose, in writing, potential conflicts of interest. This
has been added to Grant Terms and Conditions.
* §200.113.
Mandatory Disclosures. Requires non-federal entities to disclose, in writing,
any violations of criminal law. Non-federal entities should review this section
to ensure they understand their reporting obligations.
* §200.303
Internal Controls. Requires non-federal entities to establish and maintain
effective internal controls over the award and ensure that the non-federal
entity is managing the award in compliance with applicable federal statutes,
regulations, and the terms and conditions of the award.
* §§200.317-200.326.
Contracts must be procured in accordance with the procurement requirements in 2
CFR Part 200. Alternatively, nonprofit organizations and institutions of higher
education may continue to comply with the Procurement Standards in OMB Circular
A-110 for one additional fiscal year beginning after December 26, 2014. Such
election must be specified in the non-federal entity’s documented policies and procedures.
* §200.331
Requirements for pass-through entities. Delineates the roles and
responsibilities of those non-federal entities that further subaward federal
funds.
* §200.414
Indirect Cost. Allows non-federal entities who have never had a negotiated indirect
cost rate to utilize a de minimis indirect cost of 10% of Modified Total Direct
Costs. Additionally, non-federal entities that do have an indirect cost rate
may apply for a one-time extension of their current indirect cost rate for up
to four years. Guidance on how to select and calculate the de minimis rate will
be published via application instructions and eGrants account maintenance
directives.
* §200.501.
Audit Requirements. Raises the single audit threshold to $750,000; therefore, some
non-federal entities that were required to conduct an A-133 audit in the past
will no longer be required to do so. These non-federal entities will now be
monitored under CNCS’s standard operating procedures for organizations that
fall below the threshold.
CNCS will continue to communicate with you about the Uniform
Guidance and provide information on our website as FAQs are developed and updated.
In Service,
Office of Grants Management & Field Financial Management Center Corporation for National and Community Service
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