Examples
Worked examples
- Is an instance
A recipient institution's financial management system meeting the standards of §200.302 — identifying federal awards separately, comparing actual to budgeted expenditures, and maintaining source documentation.
- Is an instance
A pass-through entity performing a risk assessment of a prospective subrecipient's audit history and internal controls under §§200.331–200.333 to set the level of ongoing subrecipient monitoring.
- Is an instance
A recipient following the closeout procedures at §200.344 — submitting final financial and performance reports and settling any unspent balance within the required timeframe after the period of performance ends.
Counter-examples
Looks similar, but isn't
- Not an instance
Evaluating a proposal's budget or drafting a Notice of Funding Opportunity before an award is made — governed by Subpart C (Pre-Federal Award Requirements), not Subpart D.
- Not an instance
Determining whether a specific cost (e.g., a piece of equipment or a travel expense) is allowable, reasonable, or allocable to the award — governed by the cost principles in Subpart E, not Subpart D.
Editorial commentary
2 CFR 200 Subpart D (§§ 200.300–200.345) sets the post-award requirements a non-federal entity must follow once it accepts a federal award, covering the period between the award and its closeout. It is one of the operational subparts of the Office of Management and Budget’s Uniform Guidance, sitting between Subpart C (pre-award) and Subpart E (cost principles).
What Subpart D covers
Subpart D groups several distinct compliance areas under one heading: standards for financial and program management (internal controls, cash management, and the recipient’s obligation to monitor performance against the award’s goals); property standards for real property, equipment, and supplies acquired with federal funds; procurement standards governing how a recipient buys goods and services under the award; performance and financial reporting requirements; and, at the end of the award period, the closeout process itself, addressed specifically at 2 CFR 200.344.
Why it matters for grants administration
Because Subpart D spans the entire post-award lifecycle, a research administration or sponsored-programs office typically maps its own internal procedures — property tracking, procurement approval thresholds, subrecipient monitoring, progress-report deadlines — directly against these sections to demonstrate compliance during an audit. See CASRAI’s Closeout Costs (2 CFR 200.344) entry for the closeout-specific detail, and the 2 CFR 200 procurement standards guide for the procurement-specific requirements.
What has changed in Subpart D, and when
| Effective | What changed | Published in |
|---|---|---|
| 1 October 2024 | Recipient closeout deadline (§200.344) extended from 90 to 120 calendar days after the period of performance ends; the subrecipient-to-pass-through-entity deadline stayed at 90 days | 89 FR 30046 |
| 1 October 2024 | Equipment capitalization and disposition threshold (§200.313) raised from $5,000 to $10,000 per unit | 89 FR 30046 |
| 1 October 2024 | Fixed-amount subaward ceiling (§200.333) raised from $250,000 to $500,000 per subaward | 89 FR 30136 |
Every row above is an OMB document published in the Federal Register. Awards issued before 1 October 2024 may still carry the older 90-day closeout term or the old $5,000/$250,000 figures in their own award document — the applicable figure depends on the individual award’s issuance date, not a single universal number today.
References
- 2 CFR Part 200, Subpart D (eCFR)
- Office of Management and Budget, Uniform Guidance
- OMB, “Guidance for Federal Financial Assistance,” 89 FR 30046 (22 Apr 2024), effective 1 Oct 2024
Checking this against the current guidance
OMB publishes every change to the Uniform Guidance in the Federal Register, and the Federal Register is one of the sources Regulatory Radar checks every day — so 2 CFR 200 is one of the few subjects where CASRAI reads the primary publication venue itself rather than waiting for somebody’s summary. It does not watch the NIH Guide, and it does not watch private accreditors.
Ask CASRAI what 2 CFR 200 currently requires for an incrementally funded award straddling the October 2024 threshold changes — it answers from an indexed corpus it re-checks daily and cites the passage it used, so you can open the source and check it. Two questions a day are free while you are signed out, no account and no card. Regulatory Radar is $29 a month for 150 a day, a subscriber dashboard, API keys and MCP access. Everything CASRAI publishes, including this page, stays free to read.
Frequently Asked Questions
What sections of 2 CFR 200 does Subpart D cover?
2 CFR 200 Subpart D covers §§ 200.300–200.345 of the Uniform Guidance, spanning the entire post-award period from acceptance of a federal award through its closeout.
What is 2 CFR 200 Subpart D officially titled?
Subpart D is titled “Post-Federal Award Requirements.” It is one of the operational subparts of the Office of Management and Budget’s Uniform Guidance, positioned between Subpart C (pre-award requirements) and Subpart E (cost principles).
How does Subpart D differ from Subpart C and Subpart E?
Subpart C covers pre-award requirements and Subpart E covers cost principles; Subpart D sits between them and governs everything in between — the post-award period from when a non-federal entity accepts the award until closeout.
Does 2 CFR 200 Subpart D cover procurement standards?
Yes. Subpart D includes procurement standards governing how a recipient buys goods and services under the award. See CASRAI’s 2 CFR 200 procurement standards guide for the procurement-specific requirements.
Does Subpart D address subrecipient monitoring?
Yes. Subrecipient monitoring is one of the compliance areas a research administration or sponsored-programs office typically maps against Subpart D’s financial and program management standards to demonstrate compliance during an audit.
What happens at closeout under 2 CFR 200 Subpart D?
Closeout is the final stage of the post-award lifecycle governed by Subpart D, addressed specifically at 2 CFR 200.344. See CASRAI’s Closeout Costs (2 CFR 200.344) entry for the closeout-specific detail.
Did OMB’s 2024 revision change Subpart D, or only the cost-principles subpart?
Subpart D itself was amended in OMB’s April 2024 Uniform Guidance revision (89 FR 30046), effective for awards issued on or after October 1, 2024 — the recipient closeout deadline moved from 90 to 120 calendar days, the equipment threshold moved from $5,000 to $10,000, and the fixed-amount subaward ceiling moved from $250,000 to $500,000. These are separate from the cost-principle changes made the same day to Subpart E.
Also known as
Uniform Guidance Subpart D
Machine-readable encodings
Use in your systems
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