FEDERAL LAW FOR GRANTS AND FEDERAL SPENDING GUIDELINES

OMB Super Circular

• The Uniform Admin. Requirements, Cost Principles, and Audit Requirements for Federal Awards- referred to as Omni Circular or Super Circular

• Consolidates and streamlines eight previous fed regs into a comprehensive quidance codified at 2CFR Part 200 (Subparts A-F)

Objectives:

• Eliminate duplication and conflicting guidance

• Focus on performance over compliance

OMB SUPER CIRCULAR

• Encourage efficient use of IT and shared services

• Provide consistent and transparent treatment of costs

• Limit allowable costs to make best use of fed funds

• Set standard business processes using data definitions

• Encourage non-fed entities to have family friendly policies

• Strengthen oversight

• Target audit requirements on risk of waste, fraud, and abuse

OMB SUPER CIRCULAR

Effective dates

• Administrative requirements and cost principles apply to new awards and to additional funding to existing awards made after December 26, 2014

• Existing federal awards will continue to be governed by the terms and conditions of the federal award

• Subpart F, Audit Requirements, will apply to audits of the fiscal years of non-fed entities that begin on or after December 24, 2014

• Fiscal year end 6/30 is effective for June 30, 2016 audit

• EARLY implementation is not allowed

OMB SUPER CIRCULAR

Grant Awarding Process

• Public Notice for grants through CFDA and must include 7 data points

• Merit based review of proposals

• Risk analysis of potential grantees

• Standardization of information

• Fed awards must include 15 uniform dada sets including timing and scope, expected performance and outcomes

• Fixed Price Awards

OMB SUPER CIRCULAR

Administrative Requirements

• Integrity Rules

• Internal Controls

• Procurement

• Cost Sharing

• Subrecipient monitoring

OMB SUPER CIRCULAR

Cost Principles

• Indirect costs

• Administrative Salary Direct Costs

• Time and Effort Reporting

• Materials and Supplies

• Prior Written Approval

• Required Certifications

OMB SUPER CIRCULAR

Audit Requirements

Single Audit