This document, issued by the Council on Financial Assistance Reform (COFAR) in July 2017, is a comprehensive set of Frequently Asked Questions (FAQs) designed to clarify the Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200), commonly known as the Uniform Guidance. Serving as supplemental guidance, the document aims to assist federal agencies, states, local governments, Indian tribes, higher education institutions, nonprofits, and their auditors in consistently interpreting and implementing the Uniform Guidance, particularly in areas where regulations may be ambiguous or where significant policy changes have occurred.
The FAQs address a wide spectrum of issues, including regulatory definitions and distinctions (such as between vendors and contractors), the application and negotiation of indirect cost rates, procurement standards, audit and subrecipient monitoring responsibilities, and the treatment of software capitalization and cost allocation. The document provides detailed clarification on procurement rules by delineating requirements for micro-purchases, small purchases, and acquisitions above the simplified acquisition threshold, ensuring competitive procedures and proper documentation. It emphasizes the entitlement of entities to recover indirect costs at federally negotiated rates or the de minimis rate, delineates rules for cost sharing, and provides special guidance for specific groups such as Indian tribes and institutions of higher education.
The document also reflects OMB’s broader efforts to reform and streamline federal grant policies, consolidating disparate and sometimes conflicting guidance into a single regulatory framework. This consolidation aims to reduce administrative burden, mitigate risk of waste, fraud, and abuse, and emphasize performance-based accountability and the use of technology. Enhanced clarity around cost allowability, indirect and administrative costs, pre-award cost treatments, and audit procedures fosters greater transparency and consistency in the management of federal funds. The COFAR’s collaborative approach—incorporating extensive stakeholder feedback, offering training materials, and maintaining ongoing updates to the FAQs—underscores its commitment to effective implementation, transparency, and the facilitation of compliance. Ultimately, the document serves as a practical resource for entities managing federal awards, providing detailed, authoritative guidance to support responsible stewardship of public resources throughout the grant lifecycle.
