2016 Q3 ISSUE COSTTREE CAPTURE. 29
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Q: How much additional time will grantees need to spend on complying with the Uniform Guidance?
The Uniform Guidance requires strong, written internal controls and offers flexibilities that were not previously available to grantees. The new requirements and flexibilities may take time to implement.
However, once those procedures are in place, we do not expect that grantees and subgrantees will need more time to comply with the Uniform Guidance than is required under former regulations. More likely, given the new flexibilities available under the Uniform Guidance, the Department grantees may develop less time-consuming procedures to demonstrate compliance with the Uniform Guidance than were required under prior regulations.
The Department will assess the effect of the Uniform Guidance as it is implemented and provide feedback to OMB regarding the effectiveness of the guidance and the extent to which it reduces burden on recipients.
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Q: Does the Department have any guidance for developing written procedures for
determining allowable costs?
The Uniform Guidance places emphasis on strong internal controls. In accordance with 2 CFR 200.302, all grant recipients must have financial management systems that include written procedures for ensuring all expenditures conform to the terms and conditions of the grant as well as the Uniform Guidance Cost Principles.
The Department is developing additional training resources on internal controls that should assist entities in designing and assessing the effectiveness of such written procedures.
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Q: What are the new requirements for time and effort reporting? How will new time and effort requirements impact split-funded positions? Will tracking logs need to be changed?
The Uniform Guidance does not require any grantee to change their current system for
time and effort reporting. We know that each grantee’s system is unique.
The Uniform Guidance offers new flexibilities for time and effort tracking in an effort to reduce burden, but requires a strong internal controls program to ensure accountability. While the Department reevaluates its existing guidance and develops training resources, grantees are encouraged to contact the Department to collaboratively develop substitute time and effort tracking systems.
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Q: Does the Uniform Guidance apply to formula grants?
Yes, the Uniform Guidance applies to both formula and discretionary grants in just the
same way that former EDGAR (34 CFR) Parts 74 and 80 did. The only difference is that these regulations are now found in one place. There are some items, such as 2 CFR §§ 200.205 and 205.206, that only apply to discretionary grants and cooperative agreements, not to formula grants.
If the type of award is not specified in a particular section, subpart or group of sections, then the requirement applies to all awards.
For the most recent version of the regulations, now referred to as 2 CFR Part 200, go to