7 New Terms In 2 CFR Part 200 “Uniform Guidance”

Have you ever played buzzword bingo at your organization?

You know the game, were you see how many of the current buzzwords you can hear at the next meeting, or “visioning” session?

Words like:

• Human capital
• Synergistic
• Core competencies

The new 2 CFR Part 200 (also known as the Uniform Guidance or Super Circular) could have a similar game with all the new terminology.

In this article, I wanted to share seven of the new terms that have been incorporated into the new grant regulations.

In many cases the concepts will be familiar even if the term is new and improved.

Here are seven of our favorite new grant management terms and definitions:

(in alphabetical order)

Term #1: Computing Devices

• 200.20 Computing devices.

Computing devices means machines used to acquire, store, analyze, process, and publish data and other information electronically, including accessories (or ‘‘peripherals’’) for printing, transmitting and  receiving, or storing electronic information. See also §§ 200.94 Supplies and 200.58 Information technology systems.

This was added to the new grant regulations because (due to the decrease in computer costs and the proliferation of new “devices” such as tablets) there has been a long-running argument over whether computers were supplies or equipment.

The good news is that if the computing device cost is lower than your capitalization limit it would be a supply with far fewer tracking requirements on your Federal award.

Term #2: Compliance Supplement

• 200.21 Compliance supplement.

Compliance supplement means Appendix XI to Part 200—Compliance Supplement (previously known as the Circular A–133 Compliance Supplement).

Let’s face it; we are all in the habit of referring to the Single Act Audit as the “A-133” audit.

The new grant regulations make the A-133 reference obsolete.

Somehow “Compliance supplement audit” does NOT have the same musical ring to it, but compliance supplement is the new term we will be using.

(I have to confess, I still want to call it the A-133 audit. Lol)

Term #3: Cooperative Audit Resolution

• 200.25 Cooperative audit resolution

Cooperative audit resolution means the use of audit follow-up techniques which promote prompt corrective action by improving communication, fostering collaboration, promoting trust, and developing an understanding between the Federal agency and the non-Federal entity. This approach is based upon:

(a) A strong commitment by Federal agency and non-Federal entity leadership to program integrity;

(b) Federal agencies strengthening partnerships and working cooperatively with non-Federal entities and their auditors; and non-Federal entities and their auditors working cooperatively with Federal agencies;

(c) A focus on current conditions and corrective action going forward;

(d) Federal agencies offering appropriate relief for past noncompliance when audits show prompt corrective action has occurred; and

(e) Federal agency leadership sending a clear message that continued failure to correct conditions identified by audits which are likely to cause improper payments, fraud, waste, or abuse is unacceptable and will result in sanctions.

Now this does NOT mean that Federal award recipients and the funding agency staff are going to be holding hands and singing “Kumbaya” anytime soon.

But…the days of low levels of accountability for award recipients with repetitive audit findings (same issues year-after-year-after-year) may FINALLY coming to an end with this heightened focus on audit resolution.

Term #4: Internal Controls

• 200.61 Internal controls.

Internal controls means a process, implemented by a non-Federal entity, designed to provide reasonable assurance regarding the achievement of objectives in the following categories:

(a) Effectiveness and efficiency of operations;

(b) Reliability of reporting for internal and external use; and

(c) Compliance with applicable laws and regulations.

I am expecting a few poignant comments "Internal controls are not NEW!"

It’s true that the term “internal controls” is NOT new, the concept that everyone working on Federal awards needs to understand and support strong internal controls is a new focus.

No longer hidden away in the audit guidance or an accounting textbook, internal controls are now for everyone.

How are you spreading the word of internal control for the masses at your organization?

Term #5: Micro-Purchase

• 200.67 Micro-purchase.

Micro-purchase means a purchase of supplies or services using simplified acquisition procedures, the aggregate amount of which does not exceed the micro-purchase threshold. Micro-purchase procedures comprise a subset of a non-Federal entity’s small purchase procedures. The non-Federal entity uses such procedures in order to expedite the completion of its lowest-dollar small purchase transactions and minimize the associated administrative burden and cost. The micro-purchase threshold is set by the Federal Acquisition Regulation at 48 CFR Subpart 2.1 (Definitions). It is $3,000 except as otherwise discussed in Subpart 2.1 of that regulation, but this threshold is periodically adjusted for inflation.

This is a long…explanation highlighting part of the new procurement “bear claw” which sets various purchasing levels with requirements of competition and documentation.

A micro-purchase is the least burdensome of the procurement levels and generally applies to purchases under $3000.

Term #6: Non-Federal Entity

• 200.69 Non-Federal entity.

Non-Federal entity means a state, local government, Indian tribe, institution of higher education (IHE), or nonprofit organization that carries out a Federal award as a recipient or subrecipient.

This new term is a “one-size-fits-all” term to describe the main types of organizations that receive Federal awards.

In other words you ARE a Federal agency or you are NOT a Non-Federal Agency.

If you are NOT, then you are a non-Federal entity.  

Term #7: Protected Personally Identifiable Information (Protected PII)

• 200.82 Protected Personally Identifiable Information (Protected PII).  

Protected PII means an individual’s first name or first initial and last name in combination with any one or more of types of information, including, but not limited to, social security number, passport number, credit card numbers, clearances, bank numbers, biometrics, date and place of birth, mother’s maiden name, criminal, medical and financial records, educational transcripts. This does not include PII that is required by law to be disclosed. (See also § 200.79 Personally Identifiable Information (PII)).

So what makes PII protected?

It is the combination of information that transforms personally identifiable information into protected PII.

And remember the reference to internal controls above?

This is where the duty to protect PII comes into play because the organization (this means everyone needs to be aware of this duty) must take reasonable measures to safeguard protected personally identifiable information and other sensitive information.

The new grant regulations are updated to deal with the fact that more and more personal information is now contained online.

So do you know how and where protected PII is stored, and transmitted?

Want some help interpreting the new grant regulations?

Check out our articles on the MyFedTrainer.com blog.

We have over fifty articles about the new grant regulations about a variety of topics related to 2 CFR Part 200.

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