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Uniform Guidance (2 CFR Part 200)

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TLDR

The Uniform Guidance is the rulebook for federal grant management. If your organization receives federal awards, 2 CFR Part 200 governs what costs are allowable, how your accounting systems must work, what your procurement process must look like, and when and how you need to be audited. It applies regardless of which federal agency funded you.

The Uniform Guidance ended what was once a patchwork system where different federal agencies applied different cost principles and audit requirements to essentially the same type of award. Before 2014, a nonprofit with grants from HHS, HUD, and the Department of Education might be subject to three different cost principle frameworks, three different audit standards, and different administrative requirements for each. The Uniform Guidance replaced that with one consistent framework.

The Key Parts

Subpart A — Definitions. The definitions section establishes the precise meaning of terms used throughout the regulation. When there is any ambiguity about what a requirement means, the definitions section is the first place to look.

Subpart D — Post-Award Requirements. This is where most day-to-day grant management requirements live. It covers financial management system standards (200.302), requirements for payments (200.305), subrecipient monitoring (200.332), equipment management (200.313–200.316), and procurement standards (200.317–200.327).

Subpart E — Cost Principles. This subpart establishes the three-part test for allowable costs and contains the specific cost category sections that define what is allowable, allocable, and reasonable. Importantly, it addresses personnel costs (200.430), indirect costs (200.414), and the 30+ sections on specific cost categories — from advertising to travel to entertainment.

Subpart F — Audit Requirements. The single audit requirements, including the $1,000,000 threshold (200.501), the SEFA requirements (200.510), the risk-based major program selection approach (200.518), and the reporting package submission requirements.

The 2024 Updates

The 2024 revisions to 2 CFR Part 200 were the most significant update since the original 2014 issuance. Key changes included:

Raising the single audit threshold from $750,000 to $1,000,000 in federal expenditures, effective for fiscal years ending September 30, 2025 or later.

Updates to procurement requirements, including changes to the micro-purchase and simplified acquisition thresholds.

Revisions to the subrecipient monitoring requirements, clarifying pass-through entity responsibilities.

Organizations that had been tracking against the $750,000 threshold should update their monitoring — particularly if they are close to that figure and were relying on it as the audit trigger.

See Also

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The single audit threshold was updated from $750,000 to $1,000,000 in the 2024 revisions to 2 CFR Part 200, effective for fiscal years ending September 30, 2025 or later

Source: OMB 2024 Revisions to 2 CFR Part 200, 89 FR 30046 (April 22, 2024)

Q&A

What did Uniform Guidance replace?

The Uniform Guidance replaced three prior OMB circulars: OMB Circular A-133 (single audit requirements for states, local governments, and nonprofits), OMB Circular A-122 (cost principles for nonprofit organizations), and OMB Circular A-110 (administrative requirements for grants and agreements with nonprofits and universities). The consolidation created a single, consistent framework across federal award types.

Q&A

What is the 2024 update to the single audit threshold?

The 2024 revisions to 2 CFR Part 200 raised the single audit threshold from $750,000 to $1,000,000 in federal awards expended in a fiscal year. This change is effective for fiscal years ending September 30, 2025 or later. Organizations with fiscal years ending before that date are still subject to the $750,000 threshold for their current audit cycle.

Q&A

Where is the Uniform Guidance available?

The current version of 2 CFR Part 200 is available on eCFR.gov (Electronic Code of Federal Regulations) at ecfr.gov. The OMB website also provides access to the guidance and any published updates. The current text reflects all amendments, including the 2020 and 2024 revisions.

Frequently asked

Frequently Asked Questions

Does Uniform Guidance apply to state pass-through grants?
Yes. When a state agency (or any pass-through entity) receives federal funds and passes them to a nonprofit as a sub-award, the nonprofit is required to comply with 2 CFR Part 200 requirements applicable to non-federal entities, even though the immediate funder is the state. The pass-through entity is responsible for communicating the applicable requirements in the sub-award agreement.
What are the most important parts of 2 CFR Part 200 for a nonprofit grant manager?
For day-to-day grant management: Subpart E cost principles (especially 200.430 on personnel costs, 200.436 on depreciation, and the unallowable cost sections). For financial management: Subpart D sections on financial management (200.302), procurement (200.317–200.327), and subrecipient monitoring (200.332). For audit: Subpart F, and specifically 200.501 (threshold), 200.510 (SEFA), and 200.518 (major program determination).
What is the three-part test for allowable costs under 2 CFR 200?
Under 2 CFR 200.405, a cost charged to a federal award must be: (1) allowable — permitted under applicable cost principles and not listed as specifically unallowable; (2) allocable — it benefits the award and can be assigned to it in reasonable proportion to the benefits received; and (3) reasonable — a prudent person would recognize it as necessary and would not pay more for the same goods or services under similar circumstances.