As part of our ongoing effort to prepare nonprofit organizations for the implementation of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly known as the "Super Circular"), we devote this month's newsletter to short discussions of various aspects of the Super Circular. Specifically, we take a close look at several of the Super Circular's definitions, as well as issues to keep in mind while preparing for the Super Circular's implementation.
One of the Super Circular's notable benefits is its consolidation of eight U.S. Office of Management and Budget ("OMB") Circulars—including eight separate sets of definitions, which, over time, had begun to separately evolve and deviate from each other. These gradual definitional changes of identical terms caused conflict and confusion for nonprofits with multiple applicable Circulars. Under the Super Circular, the Federal government has harmonized these definitions and incorporated key policy decisions. Thus, the definitions, which are now truly "uniform," also represent key substantive elements to the Circular's guidance. The uniform definitions are provided at 2 CFR Subsection 200.1 through 200.99.
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