Uniform Guidance is the common name for 2 CFR Part 200, the Office of Management and Budget regulation governing how federal grants, cooperative agreements, and other federal financial assistance are administered by US universities, hospitals, nonprofits, and state and local governments. Effective December 26, 2014, it consolidated eight prior OMB circulars into six subparts, A through F.
Uniform Guidance is not itself a new concept — it is a consolidation. Before 2014, the same ground was covered by eight separate OMB circulars, each with its own numbering and, in places, inconsistent requirements: A-21 (cost principles for educational institutions), A-87 (cost principles for state, local, and tribal governments), A-102 and A-110 (administrative requirements), A-122 (cost principles for nonprofits), A-133 (audit requirements), A-89 (federal domestic assistance catalog), and the Single Audit Act guidance in A-50. OMB folded all eight into one codified regulation in Title 2 of the Code of Federal Regulations, so that a research university, a community nonprofit, and a state agency are now working from the same rulebook for the parts of the framework that apply to them, rather than cross-referencing circular-specific variants.
This page is the umbrella reference for a concept that already underpins a number of CASRAI Dictionary terms and guides — MTDC, the F&A rate, the de minimis rate, and the Single Audit are all defined by, and only make sense in reference to, specific sections of 2 CFR 200. If you arrived here from one of those pages, the sections below map directly onto where each of those concepts sits inside the regulation.
How Uniform Guidance is organized
2 CFR 200 is divided into subparts, each covering a different phase or dimension of federal award administration. Three subparts do most of the day-to-day work for a research administrator:
- Subpart A — Acronyms and Definitions (§§200.0–200.1). The controlled vocabulary the rest of the regulation relies on — this is where terms like “equipment,” “modified total direct cost,” and “subaward” get their operative definitions.
- Subpart B — General Provisions (§§200.100–200.113). Applicability, effect on other issuances, and conflict-of-interest requirements for the awarding agency.
- Subpart C — Pre-Federal Award Requirements and Contents of Federal Awards (§§200.200–200.217). What an agency must do before and while making an award, including federal awarding agency risk assessments.
- Subpart D — Post Federal Award Requirements (§§200.300–200.346). The administrative-requirements backbone: financial management standards, procurement standards, property standards, subrecipient monitoring, and reporting and record-retention requirements. This is the subpart that succeeded the old A-110/A-102 circulars.
- Subpart E — Cost Principles (§§200.400–200.476). Which costs can be charged to a federal award, and how. This is the subpart that succeeded A-21 (institutions of higher education), A-87 (governments), and A-122 (nonprofits) — Uniform Guidance’s major achievement here was harmonizing what had been three separate, not-fully-consistent sets of cost rules into one.
- Subpart F — Audit Requirements (§§200.500–200.521). The rules requiring a Single Audit of any non-federal entity that expends federal awards above a set threshold in a fiscal year — the direct successor to Circular A-133.
Twelve appendices attach to the regulation, including Appendix III (indirect cost rate determination for institutions of higher education), the reference point for the negotiated F&A rate that most research universities use instead of the de minimis rate.
The core cost principles: allowability, allocability, reasonableness, consistency
Subpart E is where most day-to-day compliance questions on a federal grant actually get resolved. Section 200.403 sets out the general criteria a cost must meet to be allowable — chargeable to a federal award at all:
- Be necessary and reasonable for the performance of the award and allocable to it;
- Conform to any limitations or exclusions in the cost principles or the specific terms of the award;
- Be treated consistently — applied uniformly to federally funded and non-federally-funded activities alike, and not charged as a direct cost on one award if an identical cost is treated as an indirect (F&A) cost elsewhere at the same institution;
- Be determined in accordance with generally accepted accounting principles (GAAP), with limited exceptions for state and local governments;
- Not be double-counted — not charged to a federal award and also used to meet a cost-sharing or matching requirement on any other federally funded program;
- Be adequately documented.
Two of those criteria have their own dedicated sections and are worth pulling out individually, since they’re the two most commonly cited in an audit finding:
Reasonableness (§200.404). A cost is reasonable if it reflects what “a prudent person” would have incurred under the circumstances prevailing when the decision to incur the cost was made — an ordinary-business-judgment standard, not a lowest-possible-price one.
Allocability (§200.405). A cost is allocable to a particular federal award if the goods or services it pays for are chargeable or assignable to that award in proportion to the relative benefit received. This is the principle that governs, among other things, how a cost gets split across multiple awards or between a project’s direct costs and an institution’s indirect costs (overheads) — and it’s the same principle behind why personnel time charged to a federal award has to reflect work actually performed on that award (see personnel cost (grant) for how this plays out in salary charging and effort certification under §200.430).
Who Uniform Guidance applies to, and who administers it
Uniform Guidance applies to any non-federal entity — a US institution of higher education, nonprofit, state government, local government, or tribal government — that receives federal financial assistance (grants, cooperative agreements) from a US federal agency. It does not, on its own, govern federal procurement contracts, which sit under the separate Federal Acquisition Regulation (FAR); it also does not directly bind non-US institutions unless a specific award’s terms and conditions incorporate it. Each federal awarding agency (NIH, NSF, DOE, etc.) issues its own implementing regulations and award terms layered on top of 2 CFR 200 — Uniform Guidance sets the floor and the common framework, not agency-specific detail like NIH’s Grants Policy Statement.
OMB owns the regulation itself; the Council on Governmental Relations (COGR), which represents US research universities and their affiliated institutions, is the most active research-administration body tracking and commenting on proposed revisions, and publishes practitioner-facing guides to specific sections (for example, its guide to §200.430 on compensation and personal services).
What changed in the 2024 revision
OMB revised 2 CFR 200 in April 2024, with the changes effective for non-federal entity fiscal years beginning on or after October 1, 2024. The two changes most visible to research administrators: the Single Audit expenditure threshold rose from $750,000 to $1,000,000 (see Single Audit for how that threshold is applied), and the threshold for the supplies/equipment-adjacent provisions in §200.314 rose from $5,000 to $10,000. OMB framed the 2024 revision, like the original 2014 consolidation, as a burden-reduction exercise — clarifying language and raising dollar thresholds that hadn’t been adjusted in a decade, rather than changing the underlying cost-principle framework.
How this connects to the rest of CASRAI’s coverage
Uniform Guidance is the regulatory source for several concepts already documented independently on this site. Rather than duplicate that content here, this page functions as the hub:
- MTDC (Modified Total Direct Cost) — the indirect-cost base defined at 2 CFR 200.1, derived directly from Subpart E.
- F&A rate (Facilities & Administrative) — the negotiated indirect cost rate mechanism set out in Appendix III to Part 200.
- Indirect costs (overheads) and indirect cost recovery — the broader concept Subpart E’s allocability rules (§200.405) are built to govern.
- De minimis rate (NIH) — the 10% MTDC-based rate available under §200.414(f) to organizations without a negotiated F&A rate.
- Single Audit (US) — the audit regime required under Subpart F for entities above the expenditure threshold.
- Personnel cost (grant) — salary and effort charging under §200.430’s compensation standards.
For the broader research-integrity and compliance landscape these pages sit inside, see the Research Integrity & Compliance cluster hub.
Frequently asked questions
Is Uniform Guidance the same thing as 2 CFR 200?
Yes — “Uniform Guidance” is the informal name research administrators use for the regulation codified at 2 CFR Part 200. Both terms refer to the same document; “2 CFR 200” is the more precise citation to use when referencing a specific section.
Does Uniform Guidance apply to universities outside the United States?
Not on its own. It governs US federal financial assistance to US-based non-federal entities and to entities that accept an award with terms and conditions that incorporate it. A non-US institution participating as a subrecipient or collaborator on a US federal award may still be bound by relevant provisions through the award’s flow-down terms, but Uniform Guidance itself is a US domestic administrative regulation, not an international standard.
What’s the difference between Uniform Guidance and the Federal Acquisition Regulation (FAR)?
Uniform Guidance (2 CFR 200) governs federal financial assistance — grants and cooperative agreements. The FAR governs federal procurement — contracts for goods and services the government purchases. Most research grants are financial assistance and fall under Uniform Guidance; a small subset of research funding structured as a federal contract falls under the FAR instead.
Where do allowability, allocability, and reasonableness come from exactly?
All three are defined within Subpart E of 2 CFR 200: allowability’s general criteria at §200.403, reasonableness at §200.404, and allocability at §200.405. A cost has to clear all three tests (plus consistent treatment) to be properly chargeable to a federal award.
Who enforces Uniform Guidance compliance?
Compliance is checked through several mechanisms working together: the awarding federal agency’s own grants management and program officers, the institution’s own internal controls and sponsored-programs office, and — above the expenditure threshold — the annual Single Audit conducted under Subpart F, which is reviewed by the relevant federal cognizant or oversight agency and made publicly available through the Federal Audit Clearinghouse.
Has Uniform Guidance changed since it was first issued in 2014?
Yes. OMB issued technical corrections in 2021 and a more substantive revision in April 2024 (effective for fiscal years beginning on or after October 1, 2024) that raised several dollar thresholds, including the Single Audit expenditure threshold. The core cost-principle structure — allowability, allocability, reasonableness, consistency — has not changed since 2014.
