2 C.F.R. Frequently Asked Questions: Using OMB’s Vital Companion Resource

Complying with the requirements of managing federal financial assistance is truly complex, and grant recipients and their subrecipients should take all steps to manage their awards effectively and compliantly and to reduce risks that could threaten their access to federal funding. However, sometimes language in the Office of Management and Budget’s (OMB) uniform guidance (2 C.F.R. Part 200), as well as other grant-related guidance in Title 2, may not be clear, and questions arise as to how these provisions should be applied. 

Although nonfederal entities that have received grants for years and are pass-through entities may be aware of OMB’s companion document, their smaller subrecipients, as well as new grant recipients and subrecipients, may not realize that the FAQ is available to help them find certain answers pertaining to Title 2 questions. This whitepaper discusses the FAQ, its structure and important updates made to it following OMB’s 2020 Title 2 revisions.