White House Office of Management & Budget Circulars

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As of 08.13.2020, final updates and addition on Grants and Agreements Guidance 

2 CFR PART 25 Universal Identifier and Systems for Award Management

UEI replaces DUNS

What is the Unique Entity Identifier (UEI)? The Unique Entity Identifier, or the UEI, is the official name of the “new, non-proprietary identifier” that will replace the D-U-N-S® number. The UEI will be requested in, and assigned by, the System for Award Management (SAM.gov).

2 CFR Part 170 Reporting Subaward and Executive Compensation Information -  Required reporting of first-tier subawards, including each action that equals or exceeds $30,000.  Such reporting will continue to be conducted through www.fsrs.gov.

2 CFR Part 183 Never Contract with the Enemy NEW - 2 CFR Part 183 Never Contract with the Enemy applies ONLY to awards exceeding $50,000.00 and performed outside the U.S., including U.S. territories.  It also applies to person or entity that is actively opposing U.S. or coalition forces involved in a contingency operation (where members of Armed Forces are actively engaged in hostilities).

2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

2 CFR 200.216 STRICT Prohibition on certain telecommunication and video surveillance services or equipment -  prohibits federal award recipients from using government funds to enter into contracts (or extend or renew contracts) with entities that use “covered telecommunications equipment or services,” even if the contract is not for the purchase of such equipment or services. Covered telecommunications equipment or services is defined as telecommunications equipment produced by:

  • Huawei Technologies Company
  • ZTE Corporation
  • Hytera Communications Corporation
  • Hangzhou Hikvision Digital Technology Company
  • Dahua Technology Company
  • any subsidiary or affiliate of such entities

Federal awarding agencies will be required to work with OMB to assist entities that will be affected by this provision. If you are concerned that your organization may have entered into contracts that would be prohibited by this provision, be sure to reach out to your contacts at the federal awarding agency or pass-through entity for further information. Contracts need to include language addressing this prohibition as well even if the contract is not intended for this purpose.  This is also applicable to the allowability criteria on procurements made in indirect cost.

2 CFR 200.344 Close-out timeframe to submit reports and liquidate obligations

  • From 90 days to 120 days
  • Deadline extension are ONLY for the PRIME recipient, NOT the subrecipient

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

On December 2014, the Office of Management and Budget (OMB) officially implemented the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. There were eight circulars combined into the Uniform Guidance (UG) and also referred to as A-81 (due to eight circulars combined into one). The consolidation was made with the intent to streamline the federal grant-making and monitoring process, to ease administrative burden for grant applicants and recipients, and to reduce the risk of waste, fraud and abuse. 

These Office of Management and Budget (OMB) circulars fall into three main categories: Administrative requirements to Sub Part A through D (A-102, A-89 & A-110), Cost Principles to Sub Part E (A-122, A-87, & A-21) and Audit Requirements to Sub Part F. Below is a summary chart for easy reference.

OMB CIRCULAR PARTICULARS Administrative requirements to Sub Part A through D
A-102 Grants and Cooperative agreements with state and local governments
A-89 Catalog of Federal Domestic Assistance
A-110

Uniform administrative Requirements for Grants and other agreements with institutions of Higher Education, hospitals and other Non-Profit Organizations

Cost Principles to Sub Part E
A-122 Cost Principles for Non-Profit Organizations
A-87 Cost Principles for State, Local and Indian Tribal Government
A-21 Cost Principles applicable to Grants and Contracts at Educational Institutions
Audit Requirements to Sub Part F
 A-133 Requirements of an audit and explains the responsibilities of the institutions the agency and the auditor
A-50 Audit Follow-up

OMB Circular A-21 - Cost Principles for Educational Institutions (05/10/2004) PDF (109 pages,b263kb)

  • A-21: This Circular establishes principles for determining costs applicable to grants, contracts, and other agreements with educational institutions. The principles deal with the subject of cost determination, and make no attempt to identify the circumstances or dictate the extent of agency and institutional participation in the financing of a particular project. The principles are designed to provide that the Federal Government bear its fair share of total costs, determined in accordance with generally accepted accounting principles, except where restricted or prohibited by law. Agencies are not expected to place additional restrictions on individual items of cost. Provision for profit or other increment above cost is outside the scope of this Circular.

OMB Circular A-110 - Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations PDF (33 pages, 243kb)

  • A-110: This Circular sets forth standards for obtaining consistency and uniformity among Federal agencies in the administration of grants to and agreements with institutions of higher education, hospitals, and other non-profit organizations.

OMB Circular A-122 - Cost Principles for Non-Profit Organizations (05/10/2004) PDF (55 pages, 220kb)

  • A-122: This Circular establishes principles for determining costs of grants, contracts and other agreements with non-profit organizations. It does not apply to colleges and universities which are covered by Office of Management and Budget (OMB) Circular A-21, "Cost Principles for Educational Institutions"; State, local, and federally recognized Indian tribal governments which are covered by OMB Circular A-87, "Cost Principles for State, Local, and Indian Tribal Governments"; or hospitals. The principles are designed to provide that the Federal Government bear its fair share of costs except where restricted or prohibited by law. The principles do not attempt to prescribe the extent of cost sharing or matching on grants, contracts, or other agreements. However, such cost sharing or matching shall not be accomplished through arbitrary limitations on individual cost elements by Federal agencies. Provision for profit or other increment above cost is outside the scope of this Circular.

OMB Circular A-133 - Audits of States, Local Governments, and Non-Profit Organizations (06/24/1997, includes revisions published in Federal Register 06/27/03) PDF (33 pages,127kb)

  • A-133: This Circular is issued pursuant to the Single Audit Act of 1984, P.L. 98-502, and the Single Audit Act Amendments of 1996, P.L. 104-156. It sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of States, local governments, and non-profit organizations expending Federal awards.