Update on 2 CFR 200 - OMB's Uniform Guidance on Assistance Awards

See also:
Links to Sources – 2 CFR 200/600/700 et al.
About 2 CFR 200
Notes on 2 CFR 600
Notes on 2 CFR 700
About 45 CFR 75

on 10 SEP 2015, OMB published 80 FR 54407 et seq., some corrections to 2 CFR 200. Among these, the most significant is probably the change to section 200.110, which extends the allowable grace period for adopting revised procurement requirements to two fiscal years following 26 DEC 2014. This may be good news for some NGOs who are feeling overwhelmend with revising their procurement policies. (See also my Notes on Procurement Policy.)

On 09 SEP 2015, COFAR published a revised, comprehensive FAQ.

On 14 AUG 2015, OMB published 80 FR 48683 typo correction for 2 CFR 200.

On 22 JUL 2015, OMB published 80 FR 43301 et seq. 22 JUL 2015 modifying 2 CFR 180 and adding bits to 2 CFR 200.

On 02 JUL 2015, DOD published 80 FR 38293 et seq. changing FAR micro purchase threshold.

On 26 DEC 2013, OMB published 2 CFR 200, the major revision to all previous circulars governing reimbursable federal awards, combining them into a single document. That announcement included COFAR's commentary on selected questions/comments that were raised during the public comment period.

Then on 19 DEC 2014, federal awarding agencies published their implementations of this uniform guidance. With few exceptions, the approach has been to codify 2 CFR 200 by reference and add specific adjustments as required by agency-specific statute and agency policy. Two key examples for the international development community are USAID's 2 CFR 700 and DOS's 2 CFR 600.

Here are my "broad-strokes" highlights of the 19 DEC 2014 changes.

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