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The U.S. Office of Management and Budget (OMB) is consolidating eight of its existing circulars into one document. This document, titled 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, is commonly referred to as the Super Circular. The Super Circular was published in the Federal Register on December 26, 2013, and is set to take effect at the end of calendar year 2014.
This webpage offers reference materials and tools for your agency to use in learning more about the Super Circular and how it impacts your agency and the federal grants you receive and administer. This page will be continually updated as guidance continues to evolve at the Federal and pass-through subrecipient levels and as more information becomes available.
The Super Circular (2 CFR, Part 200) is a substantial document, and is currently available online at the e-CFR (electronic Code of Federal Regulations). (Website)Interim Final Rule – Federal Register (Volume 79, No. 244 – December 19, 2014) OMB, together with federal agencies, has recently published a joint interim final rule to implement the final guidance on uniform administrative requirements, cost principles, and audit requirements for federal awards. The interim final rule is titled Federal Awarding Agency Regulatory Implementation of OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
The Super Circular significantly reforms federal grant making. With this document, OMB’s goals are to:
The Super Circular applies to federal agencies that make federal awards to non-federal entities such as states, local governments, non-profits, higher education institutions, hospitals, etc., as well as to non-federal entities that receive federal grant funds.
Under the Super Circular, a non-federal entity receiving federal grant funds may be a direct recipient of those funds (e.g. federal agency award to a state) or a subrecipient receiving federal funds through a subaward.
Subrecipient – Any non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program; but does not include an individual that is a beneficiary of such program. A subrecipient may also be a recipient of other Federal awards directly from the Federal awarding agency.
The Super Circular supersedes and combines the requirements of eight existing OMB Circulars from the following categories:
- Circular A-102, Grants and Cooperative Agreements with State and Local Governments
- Circular A-110, Uniform Administrative Requirements for Awards and Other Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations
- Circular A-89, Catalog of Federal Domestic Assistance (CFDA)
Reforms to Administrative Requirements are focused in the following areas:
- Conflict of Interest Guidance
- Definition of Supplies
- Pre-Award Risk Assessment
- Procurement Standards
- Performance Measurement
- Greater focus on Internal Controls
- Cost Sharing
- Requirements for Pass-Through Entities
- Mandatory Disclosures
- Circular A-21, Cost Principles for Educational Institutions
- Circular A-87, Cost Principles for State, Local and Indian Tribal Governments
- Circular A-122, Cost Principles for Non-Profit Organizations
Reforms to Cost Principles are focused in the following areas:
- Provides guidance for classifying certain costs as either Direct or Indirect
- Indirect Costs: Organizations will also be permitted to elect an automatic indirect cost rate of 10% of modified total direct costs, to be used indefinitely if they wish, or they may elect to negotiate a higher rate.
- Direct Costs: In certain circumstances, program administration costs can be reported as direct costs applicable to a specific program. Previously, grantees sometimes were required to pass these charges on via their indirect cost rates.
- Circular A-133, Audits of States, Local Governments and Non-Profit Organizations
- Circular A-50, Audit Follow-up
Reforms to Audit Requirements are focused in the following areas:
- Increased expenditure threshold for Single Audit requirement to $750,000 from $500,000
- Changes to the Risk Assessments and Major Program determination processes
- Reduction in the number of Compliance Requirements
- Modification to Reporting of Audit Findings and Questioned Costs
- Increased threshold for reporting Questioned Costs to $25,000 from $10,000
- Revised Circular Letter 15-08-OMB is effective December 26, 2014 and supersedes Circular Letter 04-04-OMB
- The new single audit expenditure threshold is applicable for recipients expending federal funds or State funds of $750,000 or greater during any fiscal year period beginning after December 26, 2014.
- Financial Statement audit requirement threshold remains at $100,000 or greater of combined federal and State expenditures for recipients not meeting Single Audit threshold.
- Revised version includes definition and language changes that are consistent with the federal Super Circular, and adds a section outlining State Cognizant Department responsibilities.
- In general, federal awarding agencies must adopt regulations implementing the Super Circular to be effective by December 26, 2014. (It is anticipated that revised federal agency specific award terms, conditions, and/or regulations may be included with any new awards or additional funding increments received for existing federal awards after this date.)
- New Federal Awards: The Super Circular’s administrative requirements and cost principles will apply to new federal awards received by the State of New Jersey (and other non-federal entities) on or after December 26, 2014.
- Incremental Funding to Existing Awards: The Super Circular requirements will also apply – in the case of federal awarding agencies that consider incremental funding actions on existing awards to be opportunities to change award terms and conditions – to the first funding increment issued on or after December 26, 2014. (Existing Federal awards that do not receive incremental funding that include new terms and conditions will continue to be governed by the original terms and conditions of the Federal award.)
- Subawards: These requirements will also apply to any subawards made by the State of New Jersey to subrecipients from new Federal awards or incremental funding received on or after December 26, 2014. The effective date of the Super Circular for subawards is the same as the effective date of the federal award from which the subaward is made. The requirements for a subaward, no matter when made, flow down from the original federal award from the federal awarding agency.
- Permitted Changes to Organization-Wide Policies: After the December 26, 2014 effective date, non-federal entities (including the State of New Jersey departments and agencies) with both old and new federal awards may make changes to their entity-wide policies and procedures to comply with the Super Circular and will not be penalized for doing so. State of New Jersey departments and agencies that administer federal awards subject to 2 CFR, Part 200 should ensure that all administrative requirements, program manuals, handbooks, and other non-regulatory materials are made consistent with the requirements of this part, except to the extent they are required by statute or authorized in accordance with the provisions in 2 CFR Part 200.102, Exceptions.
Audit Requirements – (Subpart F)
- Audit requirements detailed in Subpart F will apply to audits of non-Federal entity fiscal years beginning on or after December 26, 2014. The revised audit requirements are not applicable to fiscal years beginning prior to this date.
- The first single audit period of the State of New Jersey that will fall under the Super Circular is for SFY 2016 covering July 1, 2015 through June 30, 2016.
- The Super Circular audit requirements are effective for subrecipient audits for the fiscal year ending December 31, 2015 and periods thereafter.
- Uniform Guidance Definitions Comparison Chart
- Uniform Guidance Administrative Requirements Text Comparison Chart
- Uniform Guidance Cost Principles Text Comparison Chart
- Uniform Guidance Audit Requirements Text Comparison Chart
- Uniform Guidance Crosswalk from Existing Guidance to Final Guidance
- Uniform Guidance Crosswalk to Predominant Source in Existing Guidance
The Council on Financial Assistance Reform (COFAR) was created in October 2011 and has led several efforts to improve delivery, management, coordination, and accountability of Federal grants and cooperative agreements. OMB serves as the co-chair of this council. The COFAR website is a valuable resource for Super Circular information and webinars. To date COFAR has released two sets of FAQs to clarify and provide guidance on Super Circular changes and its implementation.
- Frequently Asked Questions (July 2017) [.pdf 955 KB]