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What the New OMB Uniform Guidance Means

The Office of Management and Budget's Uniform Guidance combines previous guidance and circulars on Administrative Requirements, Cost Principles and Audit Requirements for Federal awards into one streamlined government wide framework for grants management. The new Uniform Guidance is effective for grants and cooperative agreements awarded on or after December 26, 2014. The Uniform Guidance will not apply retroactively to existing grants. Therefore, for grants awarded prior to December 26, 2014, OJP grant recipients will follow OMB guidance and the OJP Financial Guide in effect as of the award date for each particular grant. For grants awarded on or after December 26, 2014, grant recipients must follow the new Uniform Guidance and the new DOJ Financial Guide. The new DOJ Financial Guide, to be released in March 2015, will include updates to reflect changes implemented by the new OMB Uniform Guidance. Until this time, the existing OJP Financial Guide, to the extent that it does not conflict with the Uniform Guidance, should be followed. Please refer to the chart below for specific Guidance applicable to your award.

Award date before December 26, 2014 Award date after December 26, 2014
Award supplemented after December 26, 2014
Guidance for Administrative Requirements and Cost Principles: 2 CRF 215 or OMB Circular A-110, 2 CFR 225, 2 CFR 220, or 2 CFR 230.  In addition, for Non-profit grantees, 28 CFR part 70 and for State and Local government, 28 CFR part 66, as existed on the award date applies. Guidance for Administrative Requirements and Cost Principles: Uniform Guidance (2 CFR 200) applies
Existing terms and conditions of award agreements will continue. Uniform Guidance determines terms and conditions for new awards and funding increments to existing awards.  For supplemental awards, the Uniform Guidance applies to the supplemental funding, and by award condition to all unobligated funding (including funding awarded before Dec. 26, 2014) on supplemented awards.  OJP anticipates including a special condition in all supplemental awards.
OMB Circular A-133 guides audit requirements for fiscal years dated:
January 1, 2014 – December 31, 2014
July 1, 2014 – June 30, 2015
October 1, 2014 – September 30, 2015
Uniform Guidance (2 C.F.R. subpart F, Audit requirement) guides audit requirements for fiscal years dated:
January 1, 2015 – December 31, 2015
July 1, 2015 – June 30, 2016
October 1, 2015 – September 30, 2016
Recipients may adjust their systems to comply with the Uniform Guidance any time after December 26, 2014, but must specify in documentation which rules they are applying.
Indirect cost rates for non-Federal entities will remain in effect until they are re-negotiated. Federal awarding agencies will use Uniform Guidance to renegotiate an indirect cost rate for a non-Federal entity for the fiscal year.
The OJP Financial Guide, 2014 edition, will apply and will be kept available on the OJP website. OJP anticipates issuing a revised Financial guide, incorporating changes required by Uniform Guidance, in March 2015.  For recipients of awards made after December 26, 2014 but before the issuance of a revised Financial Guide, the requirements of the Uniform Guidance supersede any directly conflicting portions of the existing OJP Financial Guide.
Non-profit organizations and institutions of higher education are NOT required to implement the procurement standards in 2 C.F.R. 200.317 through 200.326, until their fiscal years beginning on or after December 26, 2015.  (Though they may choose to do so earlier.)  An organization or institution that chooses to delay implementation of the new procurement standards must specify in its documented policies and procedures that it will continue to comply with OMB Circular A-110 until its first fiscal year beginning after December 26, 2015.

The Financial Guide, the online resource that compiles a variety of laws, rules and regulations that affect the financial and administrative management of your award, will become a DOJ-wide Financial Guide, inclusive of OJP, the Community Oriented Policing Services office (COPS), and the Office on Violence Against Women (OVW) financial policies and procedures.  The Financial Guide will also include specific language changes and other updates to comply with the Guidance.

Solicitations may look different to you; sections may be rearranged and you may see some new sections added, such as Type of Award, Pre-Agreement Cost Approval, and Federal Award Administration sections.  Applicants will be required to provide additional information on its organization on grant financial management (to be used as part of a federal agency review of the risks posed by applicants). You will also see clarified instructions for applying if you are experiencing technical issues with either Grants.gov or the Grants Management System (GMS).

If you receive a new award, you may notice some changes in the award documents. For example, you may see relevant CFDA names and numbers and your organization’s DUNS number on the award documents. You may see new special conditions or updated language of special conditions included on your award as well.

As OJP procedural changes are finalized, you will be able to access relevant quick reference guides, info sheets and other training materials explaining the changes in more detail here.


Date Created: February 20, 2020