What is the Super Circular?
The Office of Management and Budget (OMB), in its efforts to deliver on the promise of a 21st-Century government that is more efficient, effective and transparent, has streamlined the OMB Circulars on Administrative Requirements, Cost Principles, and Audit Requirements for all Federal awards into one document, referred to as the Super Circular. The Super Circular combines eight previous federal regulations into comprehensive guidance codified at 2 Code of Federal Regulations (CFR) Part 200 (Subparts A – F). These changes will improve administration of federal grant operations from the new uniform application process to the ‘close-out’ process. These changes modernize cost accounting, and improve the audit process, where the threshold for a Single Audit has been increased to $750,000 in annual federal expenditures. Museums not expending more than $750,000 are not required to have a Single Audit; however, the administrative requirements and cost principles still apply.
Previous OMB Circulars combined into the new Super Circular include: Cost Principles Circulars A-21 for Education Institutions; A-87, for State & Local Governments; and A-122 for Non-Profit Organizations; the Circular A-89, Catalog of Federal Domestic Assistance; the Administrative Requirements Circulars A-102, for State and Local Governments; A-110 for Institutions of Higher Education, Hospitals and Other Non-Profit Organizations; and the Circulars A-133 Single Audit Guidance and A-50 Audit Follow-up. The new Super Circular breaks down into the following subparts: Subpart A–Acronyms and Definitions; Subpart B–General Provisions; Subpart C–Pre-Federal Award Requirements; Subpart D–Post Federal Award Requirements; Subpart E–Cost Principles; and Subpart F–Audit Requirements.
What Does This Mean for Museums?
Museums need to become aware of the key changes in Pre-Award, Post Award and Audit Requirements. Program managers need to familiarize themselves with changes in allowable costs. Some previous allowable costs are now unallowable, and previous unallowable are now allowable. Procurement requirements and sub-recipient monitoring have been expanded. Entities with an approved indirect rate can now apply for a one-time extension for up to four years without further negotiation. And remember that no matter how much your museum receives in federal funds, the administrative requirements and cost principles will apply.
When Does It Take Effect?
The Super Circular took effect on December 26, 2013. The requirements must be implemented and effective December 26, 2014 for all Federal agencies. For non-Federal entities, the administrative requirements and cost principles apply to new awards, and to additional funding to existing awards, made after December 26, 2014. Existing federal awards will continue to be governed by the terms and conditions of the federal award. Super Circular Subpart F, Audit Requirements, will apply to audits of the fiscal years of non-federal entities that begin on or after December 26, 2014. For fiscal year end 12/31– effective for December 31, 2015 audit; and for fiscal year end 6/30—effective for June 30, 2016 audit. Note that early implementation is not allowed.
Where Can I Get More Information?
Information on Frequently Asked Questions can be found on Council on Financial Assistance Reform’s (COFAR) website. On January 27, 2014, COFAR held a training webcast for more than 5,000 registered viewers, on the major updates to OMB’s recently reformed guidance on Administrative Requirements, Audit Requirements and Cost Principles for Federal Financial Assistance (2 C.F.R. 200). The presenters provided the public with a comprehensive overview of the guidance, insight into the COFAR’s deliberative process during the two year development period, and addressed frequently asked questions. Links to this training can be found at cfo.gov/COFAR/.
For more in-depth information, visit the U.S. Office of Management & Budget, Grant Management Circulars webpage.
Ms. Montgomery is a Certified Public Accountant and has planned and/or developed conferences, seminars, and workshops for AAM and the Illinois CPA Society, and is a published author in both fiscal and human resource topic areas. She is the Director of Resource Allocation for the Illinois State Museum.