Uniform Guidance: An Overview of Equipment Management Requirements

If your organization has received federal grant assistance to fund an equipment purchase, the Uniform Guidance has requirements that must be followed in the use, management, and disposition of the funded equipment. The equipment management requirements of the Uniform Guidance are contained in Subpart D and specifically at 2 CFR Part 200.313. Though some of these requirements are intuitive, many are not, and they will require specific procedures to be put into place to comply.

Defining Equipment

To start, equipment is defined as “tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-federal entity for financial statement purposes or $5,000 (2 Code of Federal Regulations (CFR) Part 200.1).”

In addition,

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Subrecipient Monitoring – The “Must” and the “Should”

When your organization passes along federal funding to another organization (as a subrecipient), you also pass the compliance requirements on to them and become a pass-through entity. But is that where your responsibility ends? Unfortunately, the answer is no.

So, how do you ensure the compliance requirements are being followed by the organization you passed the funds through to?

The Office of Management and Budget (OMB) solved this question by the creation of the subrecipient monitoring compliance requirement in 2.CFR.200 Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards (Uniform Guidance).

In Uniform Guidance there are items that are considered a “must” and there are items considered a “should.” When Uniform Guidance suggests you “should” do something,

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Understanding the Uniform Guidance: A Federal Award Primer

Federal Awards – Strings Attached

The historic amount of federal assistance being granted in response to the COVID-19 pandemic means that many not-for-profit organizations are either receiving federal award assistance for the first time or are significantly expanding their existing portfolio of federal awards. Whether being received directly from federal awarding agencies or being received as a subrecipient from a pass-through agency, federally funded awards come with strings attached, unlike any other non-federal grant an organization will likely receive.

When applying for a federally funded award or reviewing an award agreement, understanding the requirements your organization will be held to is key to ensuring you stay on the “good side” of the federal award.

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Comprehensive Overview of Section 889 for Not-for-Profit Federal Contractors and Grant Recipients

The Office of Management and Budget (OMB) recently issued Frequently Asked Questions regarding the implementation of Section 889(b) of the National Defense Authorization Act (NDAA) of Fiscal Year 2019. If you’re part of a not-for profit organization, you may be asking yourself, “What is the Prohibition on Covered Telecommunications and Video Surveillance Services or Equipment covered in Section 889 of the NDAA, and what do we need to do?”

In this article, we will provide an overview of this provision, including how it differs between Federal contractors and Federal grant recipients, and steps your organization should be taking to ensure you comply.

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