Benefits
Know where you stand
Understand how your current operation aligns to your award T&Cs, 2 CFR 200 and supplemental agency requirements — before gaps cost you funding.
- Current state assessment
- Business system health check report
Protect every dollar
Build capability needed to protect your funding by embedding compliance into your day-to-day operation with customized or off-the-shelf infrastructure that adheres to award requirements.
- Policy & procedure development
Win funding with stronger bids
Position yourself for successful funding outcomes with solicitations and bids, aligned to 2 CFR 200 standards, with optionality for outsourced support.
- Outsourced procurement
- Solicitation & bid development
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success stories
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Nonprofit Organization
Maintained compliance while balancing efficiency to successfully complete competitive procurements with fully outsourced support
Read moreFAQs
Can’t find what you’re looking for?
What is federal grant compliance?
Federal grant compliance is the process of ensuring that an organization’s use of federal award funds conforms to the terms and conditions of the award, applicable statutes, and federal regulation such as Uniform Guidance (i.e., 2 CFR 200). There are different standards for each type of program, but most programs will have a set of rules and requirements, standards for documentation, progress tracking, process for assessing program impact, and reporting of data.
When was the last revision to Uniform Guidance (2 CFR 200)?
In April of 2024, the Office of Management and Budget (OMB) published its latest revisions to Uniform Guidance, marking only the second time that Uniform Guidance has been updated since originally being implemented in December of 2014. OMB’s 2024 revisions took effect for all new awards entered into either on or after October 1, 2024. Additionally, existing awards are subject to the 2024 revisions if later amended by federal agencies on or after October 1, 2024. OMB’s 2024 revisions included wide sweeping changes to regulatory terminology, cost thresholds, standards for internal controls, and various post-award administrative requirements.
What revisions to Uniform Guidance (2 CFR 200) should organizations be aware of?
OMB’s 2024 revisions introduced a wide scope of changes to Uniform Guidance. The following are a few examples of impactful provisions to recipients and subrecipients:
- §200.217 expanded on the whistleblower protections and requirements for recipients and subrecipients of federal awards. These expanded requirements state that recipients and subrecipients must inform their employees in writing of the Federal whistleblower protections provided to them by law.
- §200.303 introduced broader requirements for cyber security outside of the handling of personally identifiable information (PII). We can expect further expansion of cyber security requirements to be implemented by both OMB and Federal agencies.
- §200.333 fixed amount subawards can now be issued up to $500,000. An increase from the previous limit of $250,000
- §200.414(f) the De Minimis rate election was increased from 10% to 15% of modified total direct cost (MTDC). Additionally, the MTDC allocation base now allows for the inclusion of subawards up to $50,000 for each subaward issued.
- §200.501(a) the trigger for Single Audits was increased from $750,000 to $1,000,000 for federal expenditures incurred in a particular fiscal year by a non-federal entity.
Who is subject to 2 CFR 200?
2 CFR 200 applies to all recipients and subrecipients receiving federal awards, including states, local governments, Indian tribes, institutions of higher education, nonprofit organizations, and for-profit entities. However, for-profit entities are not subject to Subparts E and F as these sections specifically apply to “non-federal entities” which excludes for-profit entities. Rather, for-profit entities are subject to the contract cost principles for commercial entities located under the FAR at 48 CFR Part 31 in place of 2 CFR 200, Subpart E. Additionally for-profit entities will be required to comply with the compliance audit requirements imposed under Federal agency supplemental regulations such as 2 CFR 900 applicable to Department of Energy funded awards in place of 2 CFR 200, Subpart F.
What is a Single Audit and when is it required?
A Single Audit, governed by 2 CFR 200, Subpart F, is required for non-federal entities that expend $1 million or more in federal expenditures in a fiscal year, following the threshold increase included as part of OMB’s 2024 revision to Uniform Guidance from the prior $750,000 threshold. The audit must be performed by an independent auditor and be initiated by the recipient or subrecipient. Under a Single Audit, an auditor will evaluate both the organization’s financial statements as well as its compliance with requirements applicable to Federal awards. Findings issued through the Single Audit process are reported in the Federal Audit Clearinghouse database and are visible to all federal awarding agencies as well as the public. A pattern of repeat findings or material weaknesses in internal controls can affect an organization’s ability to receive future federal funding.
What are the subrecipient monitoring obligations for pass-through entities?
Under 2 CFR 200.332, pass-through entities are responsible for ensuring that federal award requirements flow down to subrecipients and that subrecipient performance is monitored throughout the award period. Obligations include conducting a risk assessment prior to subaward execution, establishing subaward agreements that incorporate all available information required for proper subaward identification, conducting annual monitoring of subrecipient financial and programmatic performance, and verifying that subrecipients maintain audit compliance consistent with 2 CFR 200, Subpart F. Pass-through entities remain accountable to the federal awarding agency for the actions of their subrecipients. Gaps in subrecipient monitoring are a recurring and significant source of findings in agency oversight reviews and Single Audits.
What triggers a federal agency compliance review or monitoring visit?
Federal awarding agencies are required to monitor recipient performance through a combination of desk reviews, programmatic monitoring, and on-site visits. Triggers for heightened scrutiny include prior audit findings, high dollar award values, new or first-time recipients, significant changes in organizational leadership or financial condition, and failure to submit timely and/or accurate financial reports or performance reports. Proactive compliance infrastructure, including documented internal controls, current policies and procedures, and complete award files, is the most effective mitigation against adverse monitoring outcomes.
Win awards with compliance
Embed 2 CFR 200 and agency requirements into your operations in weeks, positioning your team to secure awards and maintain compliance throughout the lifecycle.