Uniform Guidance

The Uniform Guidance is a set of regulations, located in the Code of Federal Regulations at 2 CFR 200. It provides the overarching guidelines for administering Federal awards and expenditures.  This guidance provides both federal agencies and the entities that receive federal funds a set of standard guidance for determining the allowability of charges to federal funds.  As a recipient of federal funds we should all be very familiar with its principles.

2 CFR 200 consolidates federal guidelines that was formerly part of OMB Circulars A-21 (Cost principles for Educational Institutions), A-110 (Grants and Agreements with Institutions of Higher Education) and A-133 (Audit Requirements).  The Uniform Guidance applies to all new federal awards issued on or after December 26, 2014.

Internal Controls

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Navigating the Uniform Guidance

The UG is broken down into its following subparts. The preamble also provides a useful framework and discussion of how certain guidelines were ultimately determined.

• Preamble – Major Policy Reforms
• Subpart A – Acronyms and Definitions
• Subpart B – General Provisions
• Subpart C – Pre Award Requirements
• Subpart D – Post Award Requirements
• Subpart E – Cost Principles
• Subpart F – Audit Requirements

Basic Considerations of the UG

Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards (200.403):

1. Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
2. Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
3. Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
4. Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
5. Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
6. Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period.