Changes to Federal Subaward Regulations

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Your friends in the JHSPH Office of Research Administration want to make everyone aware of two policy changes concerning federal subawards.

First, regarding USAID grants and cooperative agreements, dialogue occurring during recent federal audits has led to a University determination that all outgoing fixed price subawards must be approved in advance by USAID,  regardless of the dollar amount.  If you anticipate needing a fixed price subaward, please let us know as soon as possible so that we can contact USAID and obtain that permission.

Second, there has been a shift in direction/guidance based upon changing laws.  The Office of Management and Budget (OMB) has recently overhauled the regulations that govern the life of federal awards. OMB Circulars A-21, A-110 and A-133 have been combined into one new “Omni-Circular”, codified at 2 CFR 200, which goes into effect on December 29, 2014, which contains some very important changes  for all of us regarding audits, cost accounting, and subawards.  One significant change that impacts subawards is that fixed price subawards are allowable only if they are $150,000 or less, and only with permission from the granting agency. (See §200.332 Fixed amount Subawards.)

This explicit statement indicates that subawards valued over $150,000 cannot be fixed price. Please note that this applies to ALL federal awards, including USAID, NIH and other federal agencies, and the full text of the new 2 CFR 200 can be found here.  While the new Omni-Circular does not go into effect for several months, we are moving towards following these requirements now so that all awards will be in compliance as of December 29, 2014.

ORA is committed to working with you to ensure effective compliance of all subawards.  Please do not hesitate to contact us if you have any questions or need assistance with a new subaward that will be issued pursuant to this guidance.

One thought on “Changes to Federal Subaward Regulations

  1. Thanks JHU ORA. Will share with the NCURA Community on next weeks Magazine e-Xtra. Will you send subs on for approval prior to 12/2014? or get your processes in place to do so?

    Dan Nordquist

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