Federal Grant Reform Is Here!

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Introduction

The train en route to federal grant reform has reached the last stop on a 24-month journey from concept, through proposed reforms, to the final guidance. The new provisions—just over 100 pages—became official on December 26, 2013, with their publication in the Federal Register (pp. 78590-78691).

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The Office of Management and Budget (OMB) and its counterpart, the Council on Federal Assistance Reform (COFAR), held a national webinar on December 20, 2013, to release a pre-publication version of the final guidance ahead of the December 26th official publication date.

 

The webinar briefing unveiled the long-awaited grant reform changes, popularly known as the “super circular,” concurrently to both the grant awarding agencies and the recipient community.

 

The final guidance ushers in a series of wide-ranging changes for grants acquisition and post-award grant administration. As issued, the super circular codifies all grant guidance within Title 2 of the Code of Federal Regulations (CFR). It will be formally cited as 2 CFR Part 200 and includes six sub-parts (A-F) and eleven appendices.

 

The biggest question for recipients is this: What will these many changes do for and to me? In a series of eight blogs, of which this is the first, The Grantsmanship Center will explain the practical impact of the grant reforms on grantseekers and grant managers.

 

Transition and Implementation of the Super Circular

The super circular became effective and binding on the federal awarding agencies as of its announcement on December 26, 2013. Next, drafts of the implementing regulations by each awarding agency are due to OMB for their review in June of 2014. Finally, by December 26, 2014—one year after the announcement of the reforms—the awarding agencies are required to implement the super circular as regulations in their respective agency sub-chapters within Title 2 of the CFR (see 2 CFR 200.106).

 

Based on this timetable, one might expect to see the awarding agencies roll out their implementing regulations between July and December of 2014. At the national webinar held by OMB and COFAR, the listening audience was advised that the super circular would apply to grant awards after the 2014 adoptions by the granting agencies.

 

What then is the status of the superseded circulars on grant administration, cost management, and audits? The short answer is that all the audit, administrative, and cost circulars will retain their applicability to grants and audits during the transition to the super circular guidance but will fade away over the year as each awarding agency adopts and implements the super circular guidance in the Federal Register.

 

The following is an outline of this super circular’s components:


Code of Federal Regulations, Title 2, Part 200 (2 CFR 200)

 

Sub-Part

Sections

Pages

Topic

Sub-Part A

200.0 to 200.99

78611 to 78617

Acronyms and Definitions

Sub-Part B

200.100 to 113

78617 to 78621

General Provisions

Sub-Part C

200.200 to 211

78621 to 78624

Pre-Award Provisions and Content of Federal Awards

Sub-Part D

200.300 to 345

78624 to 78639

Post Award Requirements

Sub-Part E

200.400 to 475

78639 to 78662

Cost Principles

Subpart F

200.500 to 521

78662 to 78672

Audit Requirements

Appendices I to XI

 

78672 to 78691

 


—Henry Flood, Senior Advisor

 

 

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