2 CFR Part 200 Overview for Grantees - 2 cfr 200 property inventory

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• (1) 2 cfr 200 property disposition
• (2) 2 cfr 200 property inventory
• (3) 2 cfr 200 real property
• (4) 2 cfr 200 property standards

2 CFR Part 200 Overview for Grantees
Grants Management & Oversight Division/Office of Strategic Planning and Management
KEY DEFINITIONS
Definitions were revised and broadened to cover all the requirements and the categories of
assistance.
Cognizant Agency.
Generally, the cognizant agency is the Federal agency with the largest dollar value of
total Federal awards with a governmental unit or nonprofit entity. (See 2 CFR 200.19).
The cognizant agency is the lead agency that a non-Federal entity deals with on issues.
For example, the lead agency for some HUD recipients for indirect cost rates may be
HHS if HHS provides the most funding to the recipient. (See also the explanation under
?200.108. Inquiries). The cognizant agency for audit is the Federal agency designated to
carry out the responsibilities for audit. (See 2 CFR 200.18.)
Contractor. (New)
Contractor is used rather than the term "vendor," which was used in OMB Circular A-
133. (New) Contractor means an entity that receives a contract. (See 2 CFR 200.23) This
definition is revised, as the new definition looks at the nature of the relationship, rather
than what the document/agreement is called (2 CFR 200.22.) (See also 2 CFR 200.330.
Subrecipient and contractor determinations. )
Federal financial assistance.
This section essentially incorporates the requirements in the previous OMB circular for
the administrative requirements, cost principles, and audit requirements. (See 200.40)
Federal award.
Federal award, depending on the context, can mean either (a) the Federal financial
assistance, or (b) the document that provides the assistance, e.g. the grant, cooperative
agreement or cost reimbursement contract. (See 2 CFR 200.38)
Fixed Amount Award. (New)
In this type of award, the Federal Agency or pass through entity provides a specific level
of support without regard to actual costs incurred. Accountability is based primarily on
performance and results. (See 2 CFR 200.45.)
Micro-Purchase. (New)
This is a new category of supplies or services which uses simplified acquisition
procedures that can be used by non-Federal entities. The micro-purchase threshold
(floor) is set by the Federal Acquisition Regulation. (See 48 CFR 2.101) At the present
time, it is generally $3,000. The threshold is periodically adjusted for inflation. (See 2
CFR 200.67)
Non-Federal entity. (New)
Non-Federal entity means a state, local government, Indian tribe, institution of higher
education (IHE), or nonprofit organization that carries out a Federal award as a recipient
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or subrecipient. This is the term that is used in the regulation instead of, for example,
grantee. (See 2 CFR 200.69)
State no longer includes Indian tribe. (See 2 CFR 200.90)
Local governments, which are specifically defined, include public housing authorities.
(See 2 CFR 200.64)
Pass- Through Entity.
Pass-through entity means a non-Federal entity that provides a subaward to a subrecipient
to carry out part of a Federal program. This could include a state, which could "pass
funding through" to a county or local government, or nonprofit. (See 2 CFR 200.74)
Subrecipient.
Subrecipient means a non-Federal entity that receives a subaward from a pass-through
entity to carry out part of a Federal program. This definition is revised from the circulars.
(See 2 CFR 200.93)
HUD IMPLEMENTATION.
HUD is required to implement 2 CFR 200 unless different provisions are required by Federal
statute, are in a conforming regulation, or are otherwise approved by OMB. (See sections 2 CFR
200.102(c). 2 CFR 200.106.)
For Federal awards under 2 CFR 200 all administrative requirements, program manuals,
handbooks and other non-regulatory materials that are inconsistent with the uniform
requirements must be superseded except to the extent they are required by statute or authorized
by OMB. (See 2 CFR 200.105.) This means that handbooks and other guidance that are
inconsistent with 2 CFR 200 would need to be revised for the changes in the rule.
Federal agencies categorize Federal financial assistance as, for example, grants or cooperative
agreements, and this information will appear as the actual document. (See 2 CFR 200.101)
EFFECTIVE DATES.
The requirements in 2 CFR 200 are phased in for specific requirements in various stages as
follows: (See 2 CFR 200.110.)
Grant Agreements: Many HUD grant agreements are written to be governed by the regulations
in effect as of the date the agreement was signed.
Grants/Cooperative Agreements awarded before December 26, 2014 (the date the 2 CFR 200
rules became effective) and not modified on or after that date, are governed by 24 CFR Part 84-
Uniform Administrative Requirements for Grants and Agreements with Institutions for Higher
Education, Hospitals, and other Nonprofit organizations or24 CFR Part 85 - Administrative
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Requirements for Grants and Cooperative Agreements to State, Local and Indian Tribal
Governments, effective in December 2013.
For example, some grant agreements may contain the following language: "This Agreement will
be governed and controlled by the following, in effect as of the date of the Agreement. The Act,
the NOFA, and HUD regulations, laws and policies incorporated into the NOFA. In this case, an
agreement signed November 1, 2013, would be governed by the regulations in effect in
November, 2013.
Where the terms of a HUD award made prior to December 26, 2014, state that the award will be
subject to regulations as may be amended, the Federal award shall be subject to 2 CFR Part 200.
For example, the agreement might say: "This Agreement will be governed and controlled by the
following: the Act, the NOFA, and HUD regulations, and policies incorporated into the NOFA
as may be amended."
Procurement:
For the procurement standards in the new rule, non-Federal entities may continue to comply with
the procurement standards in previous OMB guidance for one additional fiscal year after 2014.
If a non-Federal entity chooses to use the previous procurement standards for an additional fiscal
year before adopting the procurement standards in this part, the non-Federal entity must
document this decision in their internal procurement policies.
Example: A non-Federal entity whose fiscal year ends June 30, 2015, can operate under either
the "old" or "new" standards for the fiscal year beginning July 1, 2015 and ending June 30, 2016.
Example: That non-Federal entity will be required to comply with the 2 CFR 200 procurement
standards for the fiscal year starting July 1, 2016 and ending June 30, 2017.
Audit.
Audit Requirements will apply to audits of fiscal years beginning on or after December 26, 2014.
Example: A non-Federal entity whose fiscal year ends June 30, 2015, is subject to the "new"
audit standards for their fiscal year beginning July 1, 2015 and ending June 30, 2016.
POST AWARD REQUIREMENTS AND ADMINISTRATION
Performance Measurement.
This section provides stronger guidance to Federal agencies to measure performance in a way
that will help the Federal awarding agency and other non-Federal entities to improve program
outcomes, share lessons learned, and spread the adoption of promising practices. (See 2 CFR
200.301.)
Federal awarding agencies must require recipients to use OMB-approved standard
government-wide information collections to provide financial and performance
information.
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• 2 CFR Part 200 Overview for Grantees
• Property - Purchasing, Inventory, and Disposal
• Purchasing, Inventory and Disposal of Property
• The uniform Guidance - Washington, D.C.
• §200.309 2 CFR Ch. II (1–1–14 Edition) - GovInfo