Uniform Guidance Revisions

Short video  (John Hanold & Kimberly Croft)

 

Key things everyone should know about the Revision to 2 CFR 200 (“The Uniform Guidance”)

The top ten list below is intended to highlight revisions that everyone should know about. Certain other revisions may be of interest to specific units at Penn State. (For example, if you work in Penn State Purchasing, you’ll want to check out 200.318, 319, 320, and 322. If you perform subrecipient risk assessments, you’ll want to check out 200.325 and 200.332. If you work on the Penn State audit, you’ll want to review any changes to Subpart F.)

  1. Most revisions are effective 11/12/20. (Two of the revisions—200.216 and 200.471—were effective 8/13/20.)
     
  2. Several sections of the UG have been re-numbered. (We’ll update hyperlinks in policies, hyperlinks, etc. Please let us know if you find one we’ve missed.)
     
  3. All definitions have combined into one section (200.1 Definitions).
     
  4. 200.216: We can’t use grant funds to purchase Covered Telecommunications Equipment (CTE), e.g., equipment produced by Huawei and ZTE.
     
  5. 200.105: Agencies may impose legally binding requirements only through a formal rulemaking process. They can’t implement policy changes by issuing an FAQ or issuing agency guidance that hasn’t gone through a notice and public comment process.
     
  6. 200.329 and 200.344: Allows recipients an additional 30 days to file final reports (i.e., 120 calendar days after the end of the performance period.) Subrecipients must submit their closeout reports no later than 90 calendar days after the end date of the period of performance.
     
  7. 200.340 provides the Government with more latitude to terminate projects whenever they want, even if we’ve done good work and followed all the terms and conditions.
     
  8. 200.405: If a subrecipient doesn’t have a current F&A rate agreement, we are allowed to accept their expired, previously negotiated rate. Several other options available for determining the appropriate F&A rate for subrecipients.
     
  9. 200.414 allows any entity, whether or not they’ve ever had a Federal negotiated F&A rate, to use the 10% de minimus F&A rate. No documentation is required to use this rate.
     
  10. “CFDA number” is now being called “assistance listing number.”