The new grant regulations have taken effect as of December 26, 2014.
Now the “dress rehearsal” is over and we are “live” with the new 2 CFR Part 200 Administrative Requirements, Cost Principles and Audit Standards.
Are you back from the holidays with hundreds of emails to go through?
We want to give you a quick guide to get laser-focused on the key parts of the new grant regulations.
7 Powerful Parts: 2 CFR Part 200 Uniform Guidance
Let’s look at seven key parts of the new grant regulations so you can get these changes implemented sooner, rather than later.
Part #1: Risk Assessment
The new regulations include a brand-new risk assessment that will be included in the Notice of Funding Opportunity. (NOFO)
Look for this new provision in funding opportunities and review the risk framework that Federal agencies will use to decide which non-Federal entity is the most likely to accomplish the goals of the Federal award.
- If you are a pass-through entity you also have to perform a similar risk assessment on your subawardees.
Part #2: Agency Adoption of OMB New Grant Regulations
As of the effective date of the new grant guidance, 28 Federal awarding agencies have adopted the new grant regulations into their agency regulations.
However, some of the Federal agencies included exceptions or additions to the new OMB Uniform Guidance.
You will want to go through your specific awarding agencies regulations to ensure you are meeting YOUR funding agencies requirements.
- (To download a copy of the crosswalk of additions and exceptions click here.)
Part #3: Support Women In STEM Fields
Part of the new uniform guidance is the public policy requirement to support women in the science, technology, engineering and mathematics (STEM) fields.
You may need to update your Procedures and Policies to include the new allowable costs for family-related leave, and expanded travel and conference spending.
You also may need to update your allowable cost documents to reference the new allowable costs in travel, conference and meetings and fringe benefits.
Part #4: Performance Measurements
A major objective of the new 2 CFR Part 200 is to make sure taxpayer dollars are spent to achieve results intended by the awarding of Federal dollars.
Measuring performance against award objectives is going to take on a heightened importance both in the documentation of Federal award and in the focus by your Federal program officers.
- How are you making sure that your program staff has a clear understanding of the objectives of the Federal award, and what they will be measured on by the funding agency?
Part #5: Expanded Procurement Requirements
The expansion of procurement requirements will not only affect the procurement department but potentially impact the whole organization through the key points for your organization standards of conduct and conflict of interest policy.
- If you haven’t yet compared your existing standards of conduct and conflict of interest policy against the new requirements, now is the time!
For procurement departments bringing your written procurement policies in line with the new procurement “bear claw” will be a hot topic.
Find out more in our article on the new procurement rules.
Part #6: Protecting Personally Identifiable Information (PII)
The new grant regulations have noticed that more and more of our personally identifiable information is ending up online.
And they want to make sure you are protecting the information…this means your organization now has a DUTY to safeguard how this information is stored, and transmitted when you are managing your Federal grants.
- This change involves not only grant staff, but also your IT department and others who may have access to protect personally identifiable information.
Start by determining what types of information is covered under this new requirement and then look at the steps that need to be added to protect it.
Part #7: Ensuring A Well-Trained Workforce
A top priority for COFAR and OMB is ensuring that grant staff receives the training they need to properly administer their responsibilities for safeguarding Federal dollars and meeting performance objectives for the award.
Now is the time to ask:
- How are we ensuring our current staff is adequately trained on the requirements for the new grant regulations? (In other words, how will you communicate the new requirements?)
- How are we training new employees on the requirements for spending Federal funds? (Do you have an “on-boarding” process in place for people who charge either time or spending to your grants?)
Ready to Improve Your Grant Management?
How about you?
Would you like to be a better grant manager?
We have another grant management training seminar coming soon.
Click here to get all the details!
Hope to see you there!
Lucy Morgan CPA, MBA
CEO, Compliance Warrior
Author of “Decoding Grant Management-The Ultimate Success Guide to the Federal Grant Regulations in 2 CFR Part 200” The 2nd Edition is now available on Amazon in Paperback and Kindle versions.