Uniform Guidance

What is uniform guidance?

Uniform guidance is the common name for 2 CFR Part 200, the federal regulation governing how recipients administer federal awards. It consolidated several older circulars into one rulebook covering allowable costs, procurement, internal controls, subrecipient monitoring, property standards, and audit requirements. Any organization spending federal money is subject to it, whether the funds come directly from a federal agency or pass through a state or another nonprofit.

The sections that reach small organizations first

Cost principles determine what is allowable, allocable, and reasonable. Procurement standards impose documented competition thresholds and a written procurement policy. Internal control requirements expect segregation of duties and written policies rather than informal practice. Time and effort documentation must support payroll charged to awards. Audit requirements trigger a single audit once federal spending crosses the threshold.

Building compliance before the first audit

The rules assume written policies exist: procurement, allowability, travel, cash management, conflict of interest, record retention. Organizations that adopt them only once an auditor asks have a gap for every prior year. Write the policies as you accept your first federal award, keep time records contemporaneously, and document procurement decisions when they happen. None of it is difficult in advance and most of it is impossible to reconstruct.