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2 CFR 200 Subpart B (General Provisions)

2 CFR 200 Subpart B ("General Provisions," 2 CFR 200.100-200.113) is the foundational, scope-setting subpart of the OMB Uniform Guidance. It does not itself create administrative, cost, or audit requirements the way Subparts C through F do; instead it establishes the purpose and legal authority behind the whole of 2 CFR 200, defines who and what it applies to (and what is excepted), fixes how it interacts with prior and future agency guidance, assigns OMB and federal-agency implementation responsibilities, and sets two obligations that apply across every award regardless of subject matter: a written conflict-of-interest standard (200.112) and mandatory disclosure of certain violations of federal criminal law (200.113). A requirement belongs to Subpart B if it concerns whether and how the Uniform Guidance applies at all, rather than a specific administrative, cost, or audit rule once it does apply.

ByCASRAI Editorial Board
· Last updated 23 Jul 2026

Examples

Worked examples

  • Is an instance

    A federal awarding agency incorporating 2 CFR 200 by reference into its own agency-specific regulations, as 200.106 ("Agency implementation") requires, so that a university's obligations under an NSF grant and an NIH grant rest on the same base text.

  • Is an instance

    A recipient institution's written standards of conduct for staff involved in selecting, awarding, and administering subawards or contracts, addressing conflicts of interest as required by 200.112 -- typically implemented through an institutional conflict-of-interest policy referenced in the sponsored-programs handbook.

  • Is an instance

    A recipient discovering that a subrecipient falsified cost documentation on a federal award and disclosing that violation in writing to the federal awarding agency and its Office of Inspector General, as required by 200.113's mandatory-disclosure obligation -- which applies to applicants, recipients, and subrecipients alike.

Counter-examples

Looks similar, but isn't

  • Not an instance

    A dispute over whether a specific travel cost is allowable under an award: that is a Subpart E (Cost Principles, 200.400-200.476) question, not Subpart B -- Subpart B does not adjudicate individual cost decisions.

  • Not an instance

    A requirement to submit an SF-425 Federal Financial Report or maintain a financial management system: those are Subpart D (Post-Federal Award Requirements) administrative obligations, not Subpart B.

Editorial commentary

2 CFR 200 Subpart B (“General Provisions,” §§200.100–200.113) is the opening subpart of the OMB Uniform Guidance — the part that establishes what the rest of 2 CFR 200 is, who it binds, and how it relates to other federal guidance, before any administrative, cost, or audit rule actually applies. Where Subpart D governs how an award is administered, Subpart E governs whether a specific cost is allowable, and Subpart F governs audit requirements, Subpart B sits above all of them: it is the scope-and-authority layer the other subparts assume is already in place.

What Subpart B Establishes

Subpart B’s fourteen sections fall into three functional groups.

Purpose, Scope, and Legal Basis (200.100-200.105)

  • 200.100 Purpose states that Part 200 establishes uniform administrative requirements, cost principles, and audit requirements for federal awards to non-federal entities, replacing the patchwork of OMB circulars (A-21, A-87, A-102, A-110, A-122, A-133, and related guidance) that governed federal awards before 2014.
  • 200.101 Applicability defines which federal agencies and which types of federal financial assistance the guidance covers, and identifies categories of awards — certain training awards, some awards to individuals, and other statutorily distinct instruments — that fall outside its scope.
  • 200.102 Exceptions allows OMB to approve exceptions to the guidance on a case-by-case or class basis, for example where a statute or program’s structure conflicts with a uniform requirement.
  • 200.103 Authorities identifies the statutory authority (principally the Federal Grant and Cooperative Agreement Act and related budget and procurement statutes) under which OMB issued Part 200.
  • 200.104 Supersession and 200.105 Effect on other issuances together establish that Part 200 supersedes the prior circulars and that, where an authorizing statute or program-specific regulation conflicts with Part 200, the more specific statute or regulation controls.

Implementation and Administration (200.106-200.110)

  • 200.106 Agency implementation requires each federal awarding agency to adopt Part 200 in its own regulations (with limited, OMB-approved exceptions), which is why a recipient’s obligations look consistent across NSF, NIH, DOE, and other funders rather than varying agency by agency.
  • 200.107 OMB responsibilities assigns OMB the ongoing role of interpreting Part 200, coordinating with agencies, and issuing amendments — OMB last revised the guidance in April 2024, effective for non-federal entity fiscal years beginning on or after October 1, 2024.
  • 200.108 Inquiries directs questions about the guidance to OMB.
  • 200.109 Review date commits OMB to periodically reviewing Part 200 for currency.
  • 200.110 Effective date/Effect on federal awards made prior to the effective date addresses how and when the requirements apply to awards issued before a given revision took effect, generally through agency implementing regulations and award terms rather than automatic retroactive application.

Cross-Cutting Obligations (200.111-200.113)

  • 200.111 English language requires that all Part 200 documents, and the awards issued under it, be in English unless a federal statute specifically provides otherwise.
  • 200.112 Conflict of interest requires non-federal entities to maintain written standards of conduct covering conflicts of interest in the selection, award, and administration of contracts, and to disclose in writing to the federal awarding agency or pass-through entity any real or apparent organizational conflicts of interest. This is distinct from — though related to — the individual financial-conflict-of-interest disclosure regime under 42 CFR 50 Subpart F and the institutional definitions in terms like Significant Financial Interest (SFI); 200.112 is an entity-level procurement/administration standard, not the individual investigator-disclosure rule.
  • 200.113 Mandatory disclosures requires applicants and recipients (and, by extension, subrecipients) to disclose in writing, in a timely manner, all violations of federal criminal law involving fraud, bribery, or gratuity violations potentially affecting a federal award. Failure to disclose can itself be grounds for suspension or debarment, independent of the underlying violation.

Why Subpart B Matters in Practice

Research administrators rarely cite Subpart B directly the way they cite specific cost or administrative sections — but it is the reason those other citations are consistent across funders and enforceable at all. Three practical touchpoints stand out: agency implementing regulations (verify a specific agency’s codification under 200.106 rather than assuming Part 200 language applies verbatim without agency adoption); conflict-of-interest policy language in a subrecipient or procurement policy manual, which should trace back to 200.112; and mandatory-disclosure procedures for suspected fraud, bribery, or gratuity violations, which under 200.113 create an affirmative reporting duty distinct from — and broader than — research-misconduct or financial-conflict-of-interest reporting obligations elsewhere in an institution’s compliance program.

How Subpart B Relates to the Rest of 2 CFR 200

The Uniform Guidance’s six subparts build in sequence: Subpart A defines terms; Subpart B (this page) establishes scope, authority, and cross-cutting duties; Subpart C governs the pre-award and award-making process; Subpart D governs post-award administration through closeout; Subpart E sets the cost-allowability criteria behind terms like Unallowable Cost; and Subpart F governs audit requirements, including the Single Audit threshold. For the full structure and a general-purpose overview, see CASRAI’s Uniform Guidance / 2 CFR 200 guide.

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