Accessing Funds: Section 6.1 Applicable RequirementsThe CDBG regulations require grantees that are governmental entities or public agencies to adhere to certain administrative and financial management requirements. The CDBG regulations at 24 CFR 570.489 contain basic program administrative requirements.
In late December of 2013, the federal government published a new regulation that sets forth the financial management and related requirements for federal grants (2 CFR Part 200: Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards and adopted by HUD at 2 CFR 200). It is referred to as the Omni Circular (or Super Circular) because it consolidated and replaced numerous previously applicable circulars and regulations, which include:
- OMB Circular A-87 “Cost Principles for State, Local and Indian Tribal Governments”
- Specific provisions of 24 CFR Part 85, Administrative Requirements for Grants and Cooperative Agreements to State, Local and Federally Recognized Indian Tribal Governments (the Common Rule)
- OMB Circular A-133 “Audits of Institutions of States, Local Governments and Non-profit Institutions” for fiscal 2016 forward (refer to Section 3.10 in this chapter).
2 CFR Part 200 establishes principles and standards for determining allowable costs under federal grants. It also includes requirements for audits such as the type and level of audit required, reports issued by auditors, and audit review and resolution.
Finally, it includes requirements for financial management systems, reports, records, and grant closeouts for recipients of federal grant funding. Subjects covered include financial management standards, internal controls, budget controls, accounting controls, cash management, procurement, and contracting.