Overview. Understanding the rules and requirements that govern federal funding is essential for institutions and individuals engaged in sponsored research. The following material introduces 2 CFR 200, also known as the Uniform Guidance, which outlines the administrative, financial, and compliance expectations for recipients of federal financial assistance. It also highlights key supplemental regulations and agency-specific guidance from the NSF, NIH, DOE
University procedures
and historical OMB circulars to provide a comprehensive overview of the federal regulatory landscape.
The Code of Federal Regulations on Federal Financial Assistance (2 CFR 200)
Commonly known as The Uniform Guidance, the 2 CFR 200 establishes rules for managing federal financial assistance, issued by the Office of Management and Budget (OMB). It establishes uniform standards for managing federal grants and cooperative agreements to promote transparency, accountability, and efficiency across all non-federal entities receiving federal funding. The regulation provides guidance on financial management, procurement, internal controls, cost allowability, and audit requirements to ensure consistent oversight and compliance before, during, and after a federal award is issued. The Uniform Guidance is essential for institutions of higher education, non-profits, and state and local governments, helping them responsibly manage federal funds. Below is a breakdown of the important subparts of 2 CFR 200.
Subpart A: The foundational acronyms and definitions used throughout the Uniform Guidance. By clearly defining key terms such as "Federal award," "non-Federal entity," and "cost sharing," this ensures consistent interpretation and application of the regulations. These definitions are essential for understanding roles, responsibilities, and requirements in the federal grants lifecycle.
Subpart B: The general provisions that establish the purpose, authority, and applicability of the Uniform Guidance. It clarifies which entities must follow the regulations and sets the framework for federal agencies to implement consistent policies for awarding and administering federal funds. This section also emphasizes performance-focused management and the importance of internal controls and oversight.
Subpart C: Pre-Federal Award Requirements and Contents of Federal Awards. The essential steps and information required prior to receiving a federal award. It includes guidance on funding opportunity announcements, risk evaluations of potential recipients, and the required elements of federal awards. This section ensures that all agreements are clear, transparent, and legally binding, setting the stage for effective management and accountability. By providing a standardized process, Subpart C promotes consistency in how federal funds are distributed.
Subpart D: Post Federal Award Requirements establish the guidelines for managing a federal award after funds have been received. This covers a wide range of responsibilities, including financial and program management, property standards, procurement, reporting, and subrecipient monitoring. The goal is to ensure recipients use federal funds appropriately and maintain adequate oversight and documentation.
Subpart E: Cost Principles for determining the allowability, reasonableness, and allocability of costs charged to federal awards. This provides specific guidance on direct and indirect costs, cost sharing, and unallowable expenses. These principles are critical in ensuring the financial integrity of federally funded projects and promoting transparency in budgeting and spending. Institutions must adhere to these rules to avoid audit findings and ensure continued eligibility for federal funding.
Subpart F: Audit Requirements for audits of non-federal entities that expend $750,000 or more in federal awards during a fiscal year. Commonly referred to as the Single Audit, this process evaluates both the financial statements and compliance with federal statutes, regulations, and the terms of the awards. The purpose is to provide assurance that public funds are used properly and to identify any areas for improvement or corrective action. Audit findings must be reported and addressed to maintain accountability and eligibility.
Historical OMB Circulars (A-21, A-110, A-133) and Their Relationship to the Uniform Guidance.
Prior to the issuance of 2 CFR 200, federal grant management was governed by a series of OMB Circulars, including A-21 , A-110 , and A-133. These circulars have now been superseded and consolidated into the Uniform Guidance to eliminate redundancy and simplify compliance. The transition to 2 CFR 200 represents a unified and streamlined approach to federal grants management across agencies and recipient types. Understanding the historical context of these circulars helps clarify the intent and improvements introduced by the Uniform Guidance.
NSF - PAPPG (Proposal & Award Policies & Procedures Guide)
The National Science Foundation (NSF) provides agency-specific guidance through the PAPPG, which outlines the requirements for proposal submission, merit review, and award management. It complements the Uniform Guidance by adding NSF-specific policies and procedures, such as formatting rules, participant support costs, and special compliance requirements. Researchers submitting to NSF must follow both the PAPPG and 2 CFR 200 to ensure their proposals are complete and compliant.
NIH - SF424 (R&R) Application Guide
The National Institutes of Health (NIH) uses the SF424 (Research & Related) Application Guide to detail the process of applying for NIH grants. This guide includes instructions for preparing applications, understanding review criteria, and complying with both program-specific and general federal regulations. In conjunction with 2 CFR 200, the SF424 guide ensures that NIH proposals meet all scientific, administrative, and compliance standards required by the agency.
USDA - NIFA-22-001 - Grants Application Guide
The National Institute of Food and Agriculture (NIFA) publishes funding opportunities and accepts grant application submissions through the federal Grants.gov site. The NIFA Grants Application Guide provides guidance for the preparation and submission of NIFA grant applications via the Grants.gov system. This guide provides general information and references pertaining to the grant application process as well as NIFA-specific instructions and requirements.
DOE - Portfolio Analysis and Management System (PAMS)
The Office of Science (SC) Portfolio Analysis and Management System (PAMS) is SC’s web-based system for managing proposals submitted to SC in response to funding announcements, as well as for managing the peer reviews of those proposals. PAMS has a public interface to allow for interactive search of current and past financial assistance awards. PAMS also has a User interface for Principal Investigators (PI) submitting a proposal to a solicitation and Peer Reviewers who have been invited to review proposals submitted to the Office of Science.
NASA - NSPIRES
The Solicitation and Proposal Integrated Review and Evaluation System (NSPIRES) is NASA’s online portal for browsing research solicitations—whether upcoming, open, or past—and for managing proposal preparation, submission, and peer-review participation. To utilize the system, individuals must register and, for organizational submissions, ensure affiliation with an entity already registered through SAM (System for Award Management).
DOE - G5
G5.gov is the primary portal for communication between grantees and the U.S. Department of Education. Awarded PIs must register for a G5 account and may need to verify identity via ID.me. PIs typically have roles that allow them to view and submit programmatic reports through the G5 system.
DOJ (Office of Justice) - Just Grants
The site serves as the U.S. Department of Justice’s centralized portal for its Justice Grants System (JustGrants), providing applicants and awardees with training materials, user support, frequently asked questions, and access to apply or manage grants on behalf of agencies like OJP, COPS, and OVW. It also offers resources—such as e-learning videos, reference guides, and news updates—to help users navigate the application, award acceptance, and post-award processes.
Just Grants - Justice System Grants Current Funding Opportunities
Application Submission Training Page
FAR - Contract Clauses
FAR contract clauses are standardized provisions within U.S. federal government contracts that define the rights, responsibilities, and obligations of the government and its contractors, ensuring consistency and compliance.
University-specific Policies and Procedures
Administration of Grants and Contracts in Support of Sponsored Programs Policy
At California State University, San Bernardino (CSUSB) establishes comprehensive guidelines for managing externally funded research and sponsored activities. It delineates responsibilities among university officials, departments, and auxiliary organizations to ensure compliance with applicable laws and policies. The policy outlines procedures for proposal preparation, submission, approval, and post-award administration, emphasizing the importance of coordination, fiscal accountability, and adherence to institutional and sponsor requirements.
Executive Order 1096
This outlines the systemwide policy and procedures for addressing discrimination, harassment, retaliation, sexual misconduct, dating and domestic violence, and stalking involving CSU employees and third parties. It was revised to align with federal and state laws, including Title IX, the SaVE Act, and the California Fair Employment and Housing Act (FEHA).
The CSUSB Procedure for Reporting Findings of Harassment or Sexual Assault
THis outlines how the university complies with NSF and NIH requirements to report findings of sexual harassment, other harassment, or sexual assault involving federally funded Principal Investigators (PIs) or co-PIs. Upon receipt of new or amended awards, the Office of Sponsored Programs Administration (SPA) forwards relevant information to the Research Compliance Officer (RCO), who maintains and updates a list of PIs and co-PIs in coordination with the Title IX Coordinator. If a finding occurs, the Title IX Coordinator or Human Resources must notify the Associate Provost for Research within five business days, and the university’s Authorized Organizational Representative (AOR) is responsible for notifying NSF within ten business days using their formal reporting system. The procedure ensures CSUSB’s adherence to federal guidelines promoting accountability and safe research environments
ICSUAM Section 11001
This document provides systemwide policy guidance for the administration of externally funded sponsored programs at California State University (CSU) campuses. It ensures compliance with federal regulations, including the Uniform Guidance (2 CFR 200), and outlines institutional responsibilities in key areas such as proposal review and approval, fiscal administration, subrecipient monitoring, cost sharing, effort reporting, and equipment management. Each CSU campus is required to maintain local procedures consistent with these policies while designating responsible parties, typically the university president or designee, to ensure proper implementation. The document also includes detailed definitions, roles of principal investigators, and expectations for managing conflicts of interest and responding to audits. Overall, it supports uniform and accountable grant and contract management practices across the CSU system.