Field Alert: “Supercircular” Interim Final Rule Released

By | Published On: December 22, 2014


On December 19, 2014, the U.S. Office of Management and Budget (“OMB”) along with all federal award-making agencies published the implementing regulations for the Supercircular (aka Omnicircular) in the Federal Register as a Joint Interim Final Rule.  (Vol. 79 No. 244).  The Supercircular/Omnicircular “Uniform Guidance” makes large scale changes to grants administration rules, cost principles, and audits of Federal awards.

With this Interim Final Rule, the government is making technical corrections where needed and Federal awarding agencies are joining together to implement the provisions of the Supercircular/Omnicircular (published on December 26, 2013) in their respective parts of the Code of Federal Regulations.

A PDF of the new Interim Final Rule, “Federal Awarding Agency Regulatory Implementation of Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” is available here.

In particular, the Department of Health and Human Services (“HHS”) is adapting and supplementing parts of the Supercircular/Omnicircular in its part of the Interim Final Rule based on existing HHS regulations.  HHS is creating a new 45 C.F.R. Part 75 to incorporate the implementing regulations that is intended to provide a link to the 2 C.F.R. section for HHS, 2 C.F.R. Part 300.

The field may submit written comments to on or before midnight EST on February 17, 2015.

Feldesman Tucker Leifer Fidell LLP has a variety of resources to help your organization understand the new rules.  Please visit FTLF’s training page for more on our On-Demand training options, Live Webinar training options and Live In-Person training options.  (And please note that we will be posting a series of new Training opportunities over the course of the coming months, so check back regularly.)

If you have questions or need a consultation about the new rules, please contact the Federal Grants group at Feldesman Tucker Leifer Fidell LLP, or 202-466-8960.