Multifamily Housing Program Financial Management Toolkit

3a. Implementation of the Omnibus Circular – 2 CFR Part 200

The issuance of the omnibus OMB circular (2 CFR Part 200), ‘Overview of 2 CFR Part 200: Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards,’ streamlined government guidance on administrative requirements, cost principles and audit requirements for all Federal awardees. This streamlining and reform is intended to “reduce the administrative burden for non-Federal entities receiving Federal awards while reducing the risk of waste, fraud and abuse.”

The new omnibus guidance is located in Title 2 of the Code of Federal Regulations (specifically pages 78589-78691), see: https://federalregister.gov/a/2013-30465.

Which OMB Circulars Does the Omnibus Circular Supersede?

Prior to the publication by Office of Management and Budget (OMB) in December 2014 of the omnibus circular, units of state and local government were accountable to different federal financial management guidelines from those that guided nonprofits. The omnibus circular supersedes a number of OMB’s earlier circulars, specifically:

• A-21: Cost Principles for Educational Institutions
• A-87: Cost Principles for State, Local and Indian Tribal Governments
• A-89: Catalog of Federal Domestic Assistance
• A-102: Grants and Cooperative Agreements With State and Local Governments
• A-110: Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations
• A-122: Cost Principles for Non-Profit Organizations
• A-133: Audits of States, Local Governments, and Non-Profit Organizations
• The guidance in OMB Circular A-50, Audit Follow-up, on Single Audit Act follow-up

What Else Does the Omnibus Circular Change Relative to Nonprofit Grantees and Sub-recipients?

In addition to the consolidation of OMB circulars, major audit changes include the following:

• The Single Audit threshold is raised from $500,000 to $750,000
• The questioned cost limit in Single Audits is raised from $10,000 to $25,000

The uniform guidance also removed: 2 CFR Parts 215, 220, 225, and 230. HUD adopted this guidance at a new part, 2 CFR Part 2400.
For additional information and copies of the older federal grants management guides, please visit the Office of Management and Budget's (OMB) website at: https://www.whitehouse.gov/omb/circulars/.

How Did the Issuance of the Omnibus Circular Impact Other Circulars, Such As Parts 84 and 85?

HUD amended 24 CFR parts 84 and 85, which had codified OMB Circulars superseded by 2 CFR Part 200, by removing all substantive provisions and including a saving provision that provides that Federal awards made prior to December 26, 2014, will continue to be governed by Parts 84 or 85 as codified in the 2013 edition of the Code of Federal Regulations (CFR) or as provided under the terms of a grantee’s Federal award.

How Do These Changes Impact FY 2012 PRA Grantees?

Please note that all Section 811 PRA grants awarded under the FY 2012 Notice of Funding Availability (NOFA) – and ONLY these grants – must follow the federal grant guidance presented in these older circulars, 24 CFR Parts 84 and 85.