2 CFR Part 200: The Uniform Guidance, Explained for People Who Have to Use It

Where It Came From, and Why That Still Matters

Before 2014, federal grant rules were scattered across eight separate OMB circulars. Universities lived under A-21 for costs and A-110 for administration. Nonprofits had A-122. State and local governments had A-87 and A-102. Audits were governed by A-133. The rules overlapped, sometimes contradicted each other, and used different terminology for the same concepts. It was a mess, and anyone who managed grants across multiple entity types had to keep all of it straight in their head.

The Uniform Guidance merged all of it into one regulation that applies regardless of whether you're a research university, a county health department, or a community nonprofit. That's genuinely useful. But the history still matters in one practical way: old habits and old citations linger. You'll still hear veteran grants people say "that's an A-133 audit" when they mean Single Audit, or "under A-21" when they mean the cost principles. They're talking about the same rules, just under the old names. If someone hands you guidance that cites a circular, it's outdated — anything written after December 2014 should cite 2 CFR 200.

The Six Subparts: The Only Map You Need

Here's the structure. Learn this and you can find anything in the regulation in under a minute.

Subpart A — Acronyms and Definitions (200.0–200.1). This is the dictionary. When the regulation uses a term like "equipment," "modified total direct cost," "subrecipient," or "closeout," it means exactly what 200.1 says it means — not what your accountant assumes. More compliance arguments are won and lost on definitions than on anything else. If you're not sure what a term means in a federal grant context, 200.1 is the first place you look.

Subpart B — General Provisions (200.100–200.113). Scope, applicability, the conflict-of-interest and mandatory disclosure rules. Most people skim this. The one section worth flagging is 200.113, which requires you to disclose, in writing, all violations of federal criminal law involving fraud, bribery, or gratuity. That's not optional and the penalties for sitting on it are severe.

Subpart C — Pre-Federal Award Requirements (200.200–200.216). What the agency has to do before making an award — risk assessment, the content of the Notice of Award, and the rules about who's eligible. This is more about the agency's obligations than yours, but 200.205 (the agency's review of your risk) is the reason you sometimes get extra reporting conditions attached to an award.

Subpart D — Post Federal Award Requirements (200.300–200.346). This is the big one for day-to-day management. Internal controls (200.303), financial management (200.302), payment and cash management (200.305), cost sharing (200.306), program income (200.307), budget revisions and prior approval (200.308), procurement (200.317–200.327), property and equipment (200.310–200.316), subrecipient monitoring (200.331–200.332), performance reporting (200.329), record retention (200.334), and closeout (200.344). If you spend your day managing an active grant, you live in Subpart D.

Subpart E — Cost Principles (200.400–200.476). Whether a cost is allowable. The five-part test in 200.403, the indirect cost rules in 200.414, and the ~55 "selected items of cost" in 200.420–200.476 that tell you how the government treats everything from advertising to alcohol (not allowable) to severance pay. When your accountant asks "can we charge this to the grant?" the answer is in Subpart E.

Subpart F — Audit Requirements (200.500–200.521). The Single Audit. When you need one (200.501 — the $1M threshold), what it covers, what auditors test, and what happens when they find something. Plus the appendices, including Appendix XI, the Compliance Supplement, which is what auditors actually use to test your program.

The Sections You'll Actually Cite

Out of the couple hundred sections in the regulation, a working grants manager cites maybe fifteen of them with any regularity. Here's the short list worth committing to memory:

200.303 — internal controls. 200.305 — payment, including the rule that you minimize the time between drawdown and disbursement. 200.308 — revisions of budget and program plans, which is where prior approval requirements live. 200.313 — equipment. 200.317–200.327 — procurement standards, including the micro-purchase and simplified acquisition thresholds. 200.332 — requirements for pass-through entities, the subrecipient monitoring backbone. 200.334 — record retention (three years). 200.344 — closeout. 200.403 — the factors affecting allowability of costs. 200.414 — indirect costs and the de minimis rate. 200.430 — compensation and the time-and-effort rules. 200.501 — the Single Audit threshold.

That's the working set. Everything else, you look up when you hit it.

How to Actually Read It

The free, authoritative source is eCFR.gov — the electronic Code of Federal Regulations. It's current, it's searchable, and it shows you amendment dates so you can tell which version you're looking at. Don't rely on a PDF someone emailed you in 2019. Regulations get amended, and a stale copy is how people end up citing the $750K Single Audit threshold three years after it changed.

When you open a section, read the definitions it depends on first. A section about "equipment disposition" is meaningless until you know that "equipment" in 200.1 means tangible personal property with a useful life of more than one year and a per-unit cost at or above your capitalization threshold. Half of getting the Uniform Guidance right is just getting the definitions right, and then the operative rules tend to follow logically.

Frequently Asked Questions