Council on Financial Assistance Reform (COFAR) Releases New FAQ Document on Uniform Guidance
Last Friday, the Council on Financial Assistance Reform (COFAR
) released a new, comprehensive frequently asked questions document regarding the Office of Management and Budget’s “Uniform Guidance on Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards,” also known as the Omnicircular or Supercircular. While the COFAR issued an earlier FAQ on the Uniform Guidance in February 2014, this new document includes additional information pertaining specifically to non-federal entities in areas such as procurement, indirect costs, effective date and distinctions between vendors and contractors.
To note, the document provides further clarification regarding the use of “must” versus “should” within the Uniform Guidance. Additionally, FAQ .110-6 details compliance and documentation requirements surrounding the new procurement standards, for which the federal government is providing a grace period of one full fiscal year after the effective date of the Uniform Guidance.
With the new guidance set to go into effect this December, we encourage all nonprofits to read the new FAQ document in its entirety, especially since many of the considerations it provides will be directly relevant to the single audit process. For additional information and resources to help your organization prepare for and implement the new Uniform Guidance, be sure to check out our OMB Uniform Guidance Resource Center
on the blog.