The U.S. government is committed to efficiency, effectiveness, and transparency. To achieve these goals, the Office of Management and Budget (OMB) has streamlined the guidelines for managing federal grants. This initiative, known as Uniform Grant Guidance, is designed to optimize the use of taxpayer money and enhance partnerships between federal agencies and non-federal entities. It aims to improve the impact of federal funding by focusing on better performance and clear outcomes, while also ensuring financial accountability. This reform is intended to reduce the administrative burden on organizations receiving federal awards and minimize the risks of misuse and fraud.
The uniform grant guidance is formally known as the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, detailed in 2 CFR Part 200. This comprehensive guidance replaces and simplifies rules previously found in eight separate OMB Circulars. These earlier circulars covered various aspects of federal awards:
- Administrative Requirements: These were outlined in OMB Circulars A-89, A-102 (codified in 29 CFR part 97), and A-110 (codified in 29 CFR Part 95).
- Cost Principles: Guidance on cost principles was provided by OMB Circulars A-21 (codified in 2 CFR Parts 215 and 220), A-87 (codified in 2 CFR Part 225), and A-122 (codified in 2 CFR Part 230).
- Audit Requirements: OMB Circulars A-50 and A-133 (codified in 29 CFR Parts 96 and 99) detailed the audit requirements for federal awards.
Department of Labor’s (DOL) Implementation of Uniform Guidance
The U.S. Department of Labor has adopted the uniform grant guidance with some specific adaptations. These are documented in 2 CFR Part 2900. The DOL’s adoption includes a few exceptions, approved by OMB, to maintain consistency with existing DOL policies and operational procedures.
Key Revisions in 2020 and 2021
OMB has made revisions to the uniform grant guidance (2 CFR Part 200) and related regulations in 2 CFR Parts 25, 170, 183, and 200, affecting grants and cooperative agreements. Some of these revisions became effective on August 13, 2020, with the majority taking effect on November 12, 2020.
In April 2021, the DOL issued a technical update to 2 CFR Part 2900. This update adjusted cross-references and terminology to align with the OMB’s 2020 and 2021 revisions to the uniform grant guidance, ensuring that DOL’s implementation remains current.
To support grantees and stakeholders in navigating these regulations, the Department of Labor’s Office of Grants Management (OGM) offers training and resources. They have developed technical assistance modules called SMART, which stands for Strategies for Monitoring, Accountability, Risk Mitigation, and Transparency.
These SMART training modules are designed to help recipients of DOL Federal Awards effectively manage their grants. They focus on the core principles of the uniform grant guidance (2 CFR Part 200) and the DOL’s specific implementation and exceptions (2 CFR Part 2900). These resources are available on the Grants Application and Management community page, accessible through WorkforceGPS.org.
For more in-depth information, refer to Training and Employment Guidance Letter (TEGL) No. 15-14, available at TEGL 15-14.
