Multifamily Housing Program Financial Management Toolkit

14.b  Responsibilities of PRA Grantees

Primarily as result of receiving Federal funds, PRA grantees and sub-recipients/subcontractors are required to adhere to a range of accounting principles, practices and standards. From an accounting standpoint, there are four primary sources of guidance for a grantee:

  • Generally Accepted Accounting Principles (GAAP)
  • OMB’s ‘Omnibus Circular’ (Part 200) or (for FY 2012 grantees only) Parts 84 & 85
  • PRA program guidance and contract documents
  • State and agency-specific accounting guidelines and requirements

What Is the Focus of This Toolkit Regarding Accounting Guidelines?

As existing state-sponsored agencies, PRA grantees are very likely already be operating in compliance with both GAAP and state-mandated accounting guidelines. This Toolkit focuses primarily on the federally mandated guidance included within items 2 & 3 in the list above. Our goal is to communicate these responsibilities clearly and concisely, with links to online documents where source materials and additional guidance may be found and studied.

How Is the Information in This Section Targeted?

As the overarching accounting guidelines contained in OMB circulars is covered in Parts I and II of this Toolkit, here in Section 14 we focus on guidance specific to the Section 811 PRA program:

  • The document that primarily guides accounting and grants management activities is the Cooperative Agreement (CA) between HUD and PRA grantees.
  • In addition, HUD’s Rental Assistance Contract (RAC) template, which is executed between PRA grantees and their housing ownership/management entities, also details some duties and responsibilities held by the grantee.
  • The final source document is the Notice of Funding Availability (NOFA) under which the grant funding is awarded. There can be slight differences from year to year, so it is imperative that grantees refer back to the NOFA that governs their specific PRA activities. For example, it is the NOFA that articulates which OMB circulars grantees should reference (Part 200 for FY 2013 and later vs. Parts 84 and 85 for FY 2012).

The following table outlines the applicable OMB circulars based on year of NOFA.

For PRA Activities Funded Through the FY 2013 NOFA and All Subsequent NOFAs

Uniform Financial Management Requirements

2 CFR Part 200 (OMB ‘Omnibus Circular’)

For PRA Activities Funded Through the FY 2012 NOFA Only


Governmental Agencies

Nonprofit Sub-recipients

Uniform Financial Management Requirements

24 CFR Part 85
(Implements OMB Circular A-102)

24 CFR Part 84
(Implements OMB Circular A-110)

Cost Principles

2 CFR Part 225
(supersedes OMB Circular A-87)

2 CFR Part 230
(supersedes OMB Circular A-122)

Single Audit Requirements

OMB Circular A-133