Uniform Guidance (2 CFR 200): The Governing Framework for Federal Research Grants

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.

Subpart-by-subpart navigation: which section answers your question

The subpart list above is the shape of the regulation. What most people actually arrive needing is narrower — which section covers this. 2 CFR 200 runs to roughly 220 sections, and the two largest subparts are internally organised into named section groups that the subpart headings do not show. The map below is built from the current eCFR text of Part 200. Every citation here is to a section that exists in the version in force today, not to the pre-2024 numbering.

Start here: the fastest route to the right section

If your question is about…	Go to
What a term in the regulation means	§ 200.1 (Definitions) — the single most-used section in the whole part
Whether a cost can be charged at all	§§ 200.402–200.411 (Basic Considerations), then the specific item of cost in §§ 200.420–200.476
Indirect / F&A rates, including the de minimis rate	§ 200.414, plus Appendix III (higher education) or Appendix IV (nonprofits)
Buying something with grant funds	§§ 200.317–200.327 (Procurement Standards)
Equipment, supplies, or intangible property	§§ 200.310–200.316 (Property Standards)
Issuing or monitoring a subaward	§§ 200.331–200.333 (Subrecipient Monitoring and Management)
How long to keep records	§§ 200.334–200.338 (Record Retention and Access)
Single Audit obligations and thresholds	Subpart F, starting at § 200.501
Budget changes, no-cost extensions, carryover	§§ 200.308–200.309
Termination, suspension, or an enforcement action	§§ 200.339–200.343 (Remedies for Noncompliance)
Closing out a completed award	§§ 200.344–200.346

Subpart A — Acronyms and Definitions (§§ 200.0–200.1)

Two sections only, but § 200.1 is where the operative definitions of Modified Total Direct Cost, “equipment,” “supply,” “subaward,” “recipient,” “subrecipient,” “micro-purchase threshold” and “simplified acquisition threshold” live. A surprising number of compliance disagreements resolve entirely at § 200.1 — for instance, whether an item is equipment (and so subject to the Property Standards) or a supply turns on the definitions here, not on anything in Subpart D.

Subpart B — General Provisions (§§ 200.100–200.113)

Scope and housekeeping, with two sections that carry real obligations rather than mechanics: § 200.112 Conflict of interest and § 200.113 Mandatory disclosures, which requires an applicant, recipient or subrecipient to disclose promptly and in writing — to the federal agency, its Office of Inspector General, and any pass-through entity — credible evidence of a violation of federal criminal law involving fraud, conflict of interest, bribery or gratuity violations under Title 18, or a violation of the civil False Claims Act. § 200.101 (Applicability) and § 200.102 (Exceptions) are the sections to read when the question is whether Part 200 governs a particular award at all.

Subpart C — Pre-Federal Award Requirements (§§ 200.200–200.217)

Mostly directed at the federal agency rather than at you: how funding opportunities are announced (§§ 200.203–200.204), merit review (§ 200.205), and the agency’s risk review of applicants (§ 200.206). Three sections here bind recipients directly and are frequently overlooked: § 200.210 Pre-award costs, § 200.214 Suspension and debarment, and § 200.216, the prohibition on certain telecommunications and video surveillance equipment or services. § 200.211 is the section that specifies what information a federal award must contain — useful when you need to establish what your award document should have told you.

Subpart D — Post Federal Award Requirements (§§ 200.300–200.346)

The largest administrative subpart, and the one internally divided into named groups. Those groups are the real navigation:

• §§ 200.300–200.309 — general post-award standards. Statutory and national policy requirements (200.300), performance measurement (200.301), financial management (200.302), internal controls (200.303), bonds (200.304), federal payment (200.305), program income (200.307), and revision of budget and program plans (200.308) — the prior-approval section behind most rebudgeting and carryover questions. § 200.309 covers modifications to the period of performance, which is where no-cost extensions sit.
• §§ 200.310–200.316 — Property Standards. Insurance (310), real property (311), federally owned and exempt property (312), equipment (313), supplies (314), intangible property (315), and the property trust relationship (316).
• §§ 200.317–200.327 — Procurement Standards. General standards (318), competition (319), procurement methods (320), small/minority/women’s/veteran-owned business and labor-surplus-area contracting (321), domestic preferences (322), recovered materials (323), contract cost and price (324), agency or pass-through review (325), bonding (326) and required contract provisions (327). § 200.320 sets out three method families — informal (micro-purchase and simplified acquisition), formal (sealed bids or proposals), and noncompetitive — and pegs the micro-purchase and simplified acquisition thresholds to the amounts set in the Federal Acquisition Regulation at 48 CFR part 2, subpart 2.1, rather than fixing dollar figures in Part 200 itself.
• §§ 200.328–200.330 — Performance and Financial Monitoring and Reporting.
• §§ 200.331–200.333 — Subrecipient Monitoring and Management. § 200.331 is the subrecipient-versus-contractor determination; § 200.332 sets out the pass-through entity’s obligations, including what a subaward document must contain and the requirement to honour a subrecipient’s negotiated rate or, failing that, the de minimis rate; § 200.333 covers fixed amount subawards. See subrecipient monitoring.
• §§ 200.334–200.338 — Record Retention and Access. § 200.334 sets the baseline: records must be retained for three years from the date of submission of the final financial report (or, for awards renewed quarterly or annually, three years from the relevant quarterly or annual report). The clock does not run from the project end date, which is the single most common misreading of this section. The section then lists the specific circumstances — litigation, claims, audit findings, real property and equipment records, program income — that extend it.
• §§ 200.339–200.343 — Remedies for Noncompliance, including termination (340) and the opportunity to object, hearings and appeals (342).
• §§ 200.344–200.346 — Closeout, post-closeout adjustments and continuing responsibilities, and collection of amounts due.

Subpart E — Cost Principles (§§ 200.400–200.476)

The largest subpart in the part, and the one people most often need a map of, because 57 of its sections are individual items of cost. Its five groups:

• §§ 200.400–200.401 — General Provisions. Policy guide and application.
• §§ 200.402–200.411 — Basic Considerations. The framework covered in the section above: composition of costs (402), factors affecting allowability (403), reasonable costs (404), allocable costs (405), applicable credits (406), prior written approval (407), limitation on allowance of costs (408), special considerations (409), collection of unallowable costs (410), and adjustment of previously negotiated rates containing unallowable costs (411). § 200.407 is worth knowing by number: it is the consolidated list of every activity elsewhere in the part that requires prior written approval.
• §§ 200.412–200.415 — Direct and Indirect Costs. Classification (412), direct costs (413), indirect costs (414) — including the de minimis rate at § 200.414(f) — and required certifications (415).
• §§ 200.416–200.419 — Special Considerations for States, Local Governments and Indian Tribes.
• §§ 200.420–200.476 — General Provisions for Selected Items of Cost. Fifty-seven sections, one per category, running alphabetically from advertising and public relations (421) to trustees (476). This is the part of the regulation to check before arguing a cost from first principles: if the item has its own section, that section governs.

The selected items of cost most often looked up on a research award, with their section numbers:

Item	Section
Compensation — personal services (salaries, effort)	§ 200.430
Compensation — fringe benefits	§ 200.431
Conferences	§ 200.432
Equipment and other capital expenditures	§ 200.439
Materials and supplies, including computing devices	§ 200.453
Memberships, subscriptions and professional activity costs	§ 200.454
Participant support costs	§ 200.456
Publication and printing costs	§ 200.461
Recruiting costs	§ 200.463
Travel costs	§ 200.475
Lobbying (unallowable)	§ 200.450
Entertainment and prizes (generally unallowable)	§ 200.438
Alcoholic beverages (unallowable)	§ 200.423
Bad debts (unallowable)	§ 200.426

Subpart F — Audit Requirements (§§ 200.500–200.521)

Also group-organised, and the groups tell you whose obligation a section is:

• § 200.500 — General (purpose).
• §§ 200.501–200.507 — Audits. § 200.501 carries the threshold and the single-versus-program-specific audit choice; § 200.502 covers the basis for determining federal awards expended; § 200.507 sets out the program-specific audit option.
• §§ 200.508–200.512 — Auditees. What the audited entity itself must do, including the reporting package and its submission deadline.
• § 200.513 — Federal Agencies (cognizant and oversight agency responsibilities).
• §§ 200.514–200.520 — Auditors. Audit scope (514), reporting (515), audit findings (516), and the major-program determination process (518–520) — the risk-based mechanics that decide which of an entity’s programs actually get tested.
• § 200.521 — Management Decisions.

The twelve appendices

The appendices are not commentary; several are operative. In order: I full text of notice of funding opportunity; II contract provisions for non-federal entity contracts under federal awards (the flow-down clause list); III indirect (F&A) cost identification, assignment and rate determination for institutions of higher education; IV the same for nonprofit organizations; V state/local governmentwide central service cost allocation plans; VI public assistance cost allocation plans; VII state, local government and Indian tribe indirect cost proposals; VIII nonprofit organizations exempted from Subpart E; IX hospital cost principles; X the data collection form; XI the Compliance Supplement; and XII the award term and condition for recipient integrity and performance matters. For a research university, Appendix III is the operative text for your negotiated F&A rate, and Appendix II is the list of clauses that must appear in contracts you issue under an award.

For more detail, see Intergovernmental Personnel Act — How Intergovernmental Personnel Act (IPA) assignments move personnel between federal agencies and universities: statutory basis, eligibility, duration limits, and cost/reimbursement rules.

The dollar thresholds currently in force

These are the figures in the text as it stands after the revision effective for fiscal years beginning on or after 1 October 2024. Several are commonly still quoted at their pre-2024 values:

Threshold	Current figure	Section
Single Audit requirement — federal awards expended in a fiscal year	$1,000,000 (was $750,000)	§ 200.501(a)–(b)
De minimis indirect cost rate, for entities without a negotiated rate	up to 15% of MTDC (was 10%)	§ 200.414(f)
Equipment — per-unit acquisition cost defining “equipment” rather than a supply	$10,000, or the entity’s own lower capitalization level (was $5,000)	§ 200.1
Subaward amount included in the MTDC base	first $50,000 of each subaward (was $25,000)	§ 200.1
Residual unused supplies triggering disposition obligations	$10,000 aggregate value (was $5,000)	§ 200.314(a)
Equipment fair market value below which disposal is unrestricted	$10,000 per unit (was $5,000)	§ 200.313(e)
Known questioned costs an auditor must report as an audit finding	$25,000	§ 200.516(a)(3)
Micro-purchase and simplified acquisition thresholds	Not fixed in Part 200 — set by reference to the FAR, 48 CFR part 2, subpart 2.1	§§ 200.1, 200.320

The MTDC change is the one most likely to be missed, because it is a definition rather than a headline threshold: raising the per-subaward inclusion from $25,000 to $50,000 changes the indirect-cost base on every award that issues subawards, without any change to the rate itself.

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 MTDC-based de minimis rate (up to 15% since October 1, 2024, raised from 10%) 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.

Programme-specific maintenance-of-effort requirements sit alongside these cost principles and are tested in the same audit.

Further reading: 2 CFR 200 public comment — OMB’s proposed rewrite of the Uniform Guidance (2 CFR 200) closed for comment July 13, 2026.