Part I: COFAR and the Extension of the Procurement Standards Grace Period
On September 9, 2015 the Office of Management and Budget (“OMB”) and the Council on Financial Assistance Reform (“COFAR”) released new Frequently Asked Questions (“FAQs”) and technical corrections to the Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) at 2 CFR Part 200.
In 2011, COFAR was established with the purpose of providing policy level leadership for the federal grants community and played a key part in the development and implementation of the Uniform Guidance. It is a cross-agency group composed of the OMB Controller and senior policy officials from nine other federal agencies including the Department of Health and Human Services (“HHS”), the Department of Education, and the Department of Agriculture.
COFAR continues to have an important role in clarifying the provisions of the Uniform Guidance for federal agencies and federal grant recipients (also referred to as non-federal entities or NFEs). As part of carrying out that responsibility, COFAR has released FAQs that provide valuable clarifications and, in some cases, technical corrections of the Uniform Guidance. As such, grantees should turn to these FAQs for answers on how to comply with certain Uniform Guidance provisions. The most recent FAQs include clarifications and technical corrections issued in 2014 and new information that grantees may find particularly useful.
One of the more significant technical corrections relates to the grace period for grantees to comply with federal grant procurement standards, which has been extended to two full fiscal years after the effective date of the Uniform Guidance. The effective date of the Uniform Guidance occurred on December 26, 2014, which means that if a grantee’s fiscal year end is June 30th, then that grantee would have to comply with the procurement standards by June 30, 2017. It is important to note that in HHS’ adaptation of the Uniform Guidance, the applicability of the grace period was limited only to NFEs that were previously subject to OMB Circular A-110. This means that only nonprofit organizations, hospitals and universities receiving grants from HHS would be eligible to take advantage of the grace period. See 45 CFR § 75.110.
Stay tuned for part II of our blog series where we will discuss other significant additions and amendments to the recently issued FAQs. For more information about the Uniform Guidance including any clarification from COFAR, check out our Supercircular webinar or contact us to find out more about our customized trainings.