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CASRAI

Definition · Plain-language

Uniform Guidance

Uniform Guidance is the set of OMB rules in 2 CFR Part 200 that govern how federal grants and cooperative agreements are administered, costed and audited.

CASRAI research-methods explainer — Uniform Guidance

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Why it exists

Before 2014, federal grant rules were scattered across multiple OMB circulars (such as A-21, A-110 and A-133) with different requirements for universities, states, non-profits and local governments. Uniform Guidance consolidated these into a single, harmonised framework in 2 CFR Part 200, reducing administrative burden and inconsistency. Because it brought so many circulars together, practitioners call it the “Super Circular”. It applies to most federal grants and cooperative agreements government-wide.

What it contains

The regulation is organised into subparts covering acronyms and definitions, general provisions, pre-award requirements, post-award administration, cost principles, and audit requirements (Subpart F). The cost principles define which costs are allowable, allocable and reasonable, and how to treat direct versus indirect (facilities & administrative) costs. The audit subpart sets out the Single Audit. Together these provide one rulebook from application through close-out and audit.

The 2024 revisions

OMB issued substantial revisions in 2024 to modernise and clarify the framework. Headline changes included raising the Single Audit threshold from $750,000 to $1,000,000 and increasing the de minimis indirect cost rate that entities may charge without a negotiated rate from 10% to 15% of modified total direct costs. The revisions also simplified language and strengthened plain-language drafting, and generally apply to awards issued on or after the effective date.

Key facts

At a glance

  • Definition: OMB uniform rules for federal awards
  • Citation: 2 CFR Part 200
  • Nickname: the “Super Circular”
  • Issuer: U.S. Office of Management and Budget (OMB)
  • Covers: admin requirements, cost principles, audit (Subpart F)
  • 2024 update: Single Audit $1M, de minimis indirect rate 15%

Common misconceptions

What people often get wrong

Often heard: Uniform Guidance is a law passed by Congress.

Actually: It is a federal regulation issued by OMB and codified in 2 CFR Part 200, then adopted by awarding agencies — not a statute.

Often heard: It only applies to universities.

Actually: It applies government-wide to most non-federal entities receiving federal awards, including states, local governments, non-profits and tribes.

Often heard: The de minimis indirect rate is still 10%.

Actually: The 2024 revisions raised the de minimis rate to 15% of modified total direct costs for entities without a negotiated rate.

Referenced across the research world

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