Uniform Guidance (2 CFR 200)

Definition

The Uniform Guidance is the common name for 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. The Office of Management and Budget issues it and federal agencies adopt it for their grants and cooperative agreements. Subpart D covers post-award requirements, Subpart E the cost principles, and Subpart F the audit requirements. OMB published revisions on April 22, 2024 (89 FR 30046), effective October 1, 2024. For audits, the revised Subpart F, including the $1,000,000 single audit threshold, applies to fiscal years beginning on or after October 1, 2024.

Why it matters in an audit or review

Auditors test compliance with the requirements that apply to each major program: allowable costs, cash management, procurement and suspension and debarment, subrecipient monitoring, reporting, and eligibility. The Compliance Supplement, which OMB issues each year, lists the audit procedures to use. Because the rules changed in 2024, the auditor confirms which version applies to the award and fiscal year.

Example

Illustrative: a charity charges executive travel to a federal grant. The auditor checks whether the cost principles allow it, whether the award documents approve it, and whether it was charged in proportion to the benefit.

Common mistakes

Relying on last year's Compliance Supplement for the current audit.

FAQ

Who issues the Compliance Supplement?

OMB issues it annually, and auditors use it for program-specific audit steps.

Sources

• 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards: https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200
• OMB, Guidance for Federal Financial Assistance, 89 FR 30046 (April 22, 2024), effective October 1, 2024: https://www.federalregister.gov/d/2024-07496
• OMB, Compliance Supplement (2 CFR Part 200, Appendix XI)