OMB Update – Revised Uniform Guidance 2 CFR 200: Including Performance-Based Payments, Significant Changes to the Procurement Standards and the De Minimis Rate

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The Uniform Guidance (2 CFR 200) is revised effective November 12, 2020. The Uniform Guidance provides the rules for grants and cooperative agreements funded by the U.S. Government. The revision reflects a foundational shift to focus on enhanced results-oriented accountability for grants and cooperative agreements based on performance. As a part of President’s management agenda, the revision will improve stewardship and ensure the American people receive value for Federal funds spent on various grant programs. This update will provide an example of performance initiates by demonstrating performance-based payments using unit cost rates in lieu of cost reimbursable invoicing.

Basic Course Information

Learning Objectives

• Understand the critical updates to the Uniform Guidance
• Obtain a working knowledge of how Performance-Based Payments operate with Unit Cost Rates in Lieu of cost reimbursable invoicing.
• Compare the precise language changes for the various policies and procedures
• Learn the key updates organized by each revised topic
• Ability to take action to enhance an organization’s existing procedures to conform to this important update

Major Subjects

• New and revised definitions
• Clarification on the use of time periods
• Emphasis on performance and outcomes
• Performance-Based Payments using unit cost rates in lieu of cost reimbursable invoicing
• New cost principle
• New prohibitions
• New procurement preference and refocus on public policy objectives
• Clarification on sub-recipients with no direct funding
• Relaxing the rule for NICRA to De Minimis rate usage
• The flexibility that no “one-size-fits-all” procurement standards

Mr. Calabrese has hands-on experience with the Uniform Guidance for Federal grants recipients: nonprofits, universities, hospitals, and state/local/tribal units of governments. His skill-set involves: grant cost accounting, sub-recipient monitoring, preparation of over (100) indirect rates / NICRA for several Federal agencies, developed policies and procedures, medical management systems invoicing to state Medicaid agencies and toolkit for unit cost rates for Ryan White HIV AIDS HRSA awards. Paul has developed grant and financial statement dashboards. He has performed out-sourced CFO duties, annual budgets, cash flow projections, grant draws and budget monitoring.

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