Tag Archives: CFR

Grants Update: OMB Super Circular 2 CFR Part 200

Brad Smith will co-present this Public Contracting Institute webinar on October 19. He will discuss how not-for-profit organizations receiving federal awards are subject to updated requirements stemming from the Office of Management and Budget’s “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards” of 2 CFR Part 200. Continue reading Grants Update: OMB Super Circular 2 CFR Part 200

COFAR Disbandment and the 2 CFR 200 FAQs You Need to Know

On June 15, 2017, through Memorandum M-17-26, the Office of Management and Budget (OMB) disbanded the Council on Financial Assistance Reform (COFAR). Originally established in 2011, the COFAR was an interagency group of Executive Branch officials that coordinated financial assistance on grants and cooperative agreements, integrating the uniform grant guidance (2 CFR 200), as well as ideas and best practices among executive departments and agencies. Continue reading COFAR Disbandment and the 2 CFR 200 FAQs You Need to Know

A Closer Look at the Allowability of Bid and Proposal Costs

A Closer Look at the Allowability of Bid and Proposal Costs

Bid and proposal costs[1], commonly referred to as “B&P” costs, have been at issue in the news recently, namely serving as a grounds for suspension or debarment. Contractors subject to Federal Acquisition Regulation (FAR) and Cost Accounting Standards (CAS) requirements have had clear guidance for the treatment of B&P costs, but nonprofit organizations have been operating in a grey area since 2004, when the B&P cost principle in OMB Circular A-122 was removed. The confusion arises in situations where staff who typically charge time directly to awards are asked to perform proposal activities that may not be properly recorded on the employee’s timesheet. While it may seem like the proposal activities are directly associated with one project, there are actually limited instances where this time can be charged direct. This post will take a closer look at the rules and regulations that govern B&P costs, as well as the unique circumstances that can warrant a deviation from the usual treatment. Continue reading A Closer Look at the Allowability of Bid and Proposal Costs