Introduction
The train en route to federal grant reform has reached the last stop on a 24-month journey from concept, through proposed reforms, to the final guidance. The new provisions—just over 100 pages—became official on December 26, 2013, with their publication in the Federal Register (pp. 78590-78691).
The Office of Management and Budget (OMB) and its counterpart, the Council on Federal Assistance Reform (COFAR), held a national webinar on December 20, 2013, to release a pre-publication version of the final guidance ahead of the December 26th official publication date.
The webinar briefing unveiled the long-awaited grant reform changes, popularly known as the “super circular,” concurrently to both the grant awarding agencies and the recipient community.
The final guidance ushers in a series of wide-ranging changes for grants acquisition and post-award grant administration. As issued, the super circular codifies all grant guidance within Title 2 of the Code of Federal Regulations (CFR). It will be formally cited as 2 CFR Part 200 and includes six sub-parts (A-F) and eleven appendices.
The biggest question for recipients is this: What will these many changes do for and to me? In a series of eight blogs, of which this is the first, The Grantsmanship Center will explain the practical impact of the grant reforms on grantseekers and grant managers.
Transition and Implementation of the Super Circular
The super circular became effective and binding on the federal awarding agencies as of its announcement on December 26, 2013. Next, drafts of the implementing regulations by each awarding agency are due to OMB for their review in June of 2014. Finally, by December 26, 2014—one year after the announcement of the reforms—the awarding agencies are required to implement the super circular as regulations in their respective agency sub-chapters within Title 2 of the CFR (see 2 CFR 200.106).
Based on this timetable, one might expect to see the awarding agencies roll out their implementing regulations between July and December of 2014. At the national webinar held by OMB and COFAR, the listening audience was advised that the super circular would apply to grant awards after the 2014 adoptions by the granting agencies.
What then is the status of the superseded circulars on grant administration, cost management, and audits? The short answer is that all the audit, administrative, and cost circulars will retain their applicability to grants and audits during the transition to the super circular guidance but will fade away over the year as each awarding agency adopts and implements the super circular guidance in the Federal Register.
The following is an outline of this super circular’s components:
Code of Federal Regulations, Title 2, Part 200 (2 CFR 200)
| Sub-Part | Sections | Pages | Topic |
| Sub-Part A | 200.0 to 200.99 | 78611 to 78617 | Acronyms and Definitions |
| Sub-Part B | 200.100 to 113 | 78617 to 78621 | General Provisions |
| Sub-Part C | 200.200 to 211 | 78621 to 78624 | Pre-Award Provisions and Content of Federal Awards |
| Sub-Part D | 200.300 to 345 | 78624 to 78639 | Post Award Requirements |
| Sub-Part E | 200.400 to 475 | 78639 to 78662 | Cost Principles |
| Subpart F | 200.500 to 521 | 78662 to 78672 | Audit Requirements |
| Appendices I to XI | 78672 to 78691 |
—Henry Flood, Senior Advisor
