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Uniform Guidance Brings New Rules for International Entities
Significant reforms are coming for government agencies, nonprofits, and higher education institutions applying for and receiving federal grants and cooperative agreements. This includes foreign public entities and international organizations that receive funding from the United States, and domestic organizations with overseas activities or projects under federal grants.
“This is a significant enough overhaul that organizations need to be planning for change right now,” says Rebecca Field, a nonprofit manager with CliftonLarsonAllen. “Implementing the new rules begins with an understanding of what has changed, and who the changes apply to.”
The Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards applies to all grants, or incremental funding to current grants, made after December 26, 2014, to nonprofits, colleges and universities, and state and local governments.
White Paper: “Applying Uniform Grant Guidance to International Activities” Download Now “Grant Reform and Uniform Guidance Planning and Implementation Checklist” Download Checklist
Known as Uniform Grant Guidance (UG) but previously referred to as the Super Circular or Omni Circular, the new OMB rules eliminate duplicate language found in eight circulars (A-21, A-87, A-110, A-122, A-89, A-102, A-133, and A-50) that previously applied to federal awards.
Federal awarding agencies have the option to apply portions of the new UG to foreign public entities and organizations receiving grants. In addition, pass-through entities in the United States will be pushing these regulations down to sub-recipients, who will then be required to monitor them under the UG. This includes sub-awards with foreign public entities and foreign organizations.
The new guidance includes significant reforms to current administrative requirements (formerly covered by circulars A-102, A-110, and A-89). Some of the reforms may affect international activities and projects in the areas of:
- Organizational conflict of interest
- Allowable costs
Also included are reforms to cost principles (formerly circulars A-21, A-87, and A-122):
- Administrative and clerical salaries
- Severance pay to foreign nationals
- Exchange rates
- Housing allowances and living expenses
- Security costs
- Relocation costs
- Value-added taxes
How we can help
CliftonLarsonAllen has prepared a white paper, “Applying Uniform Grant Guidance to International Activities,” to outline some of the key changes for organizations that receive federal grants to fund international projects or activities. In addition, our implementation checklist allows users to set deadlines and track progress toward full implementation of the guidelines. CLA professionals are also available to provide guidance and tools tailored to your organization’s needs, and to assist in timely compliance with the new rules.