Posted: June 2021

Topic- 2CFR200 Description Impact
.205 Merit review process The merit review process has been extended to grants and cooperative agreements, including discretionary grants. Agencies must have written standards to select recipients most likely to be successful in delivering results based on the programmatic objectives. Proposals will be evaluated in accordance with written standards established by federal agencies to meet these objectives.
.211 Performance goals Agencies must specify in terms and conditions of awards how performance will be assessed including timing and scope of expected performance. Research Performance Progress Reports (RPPRs) will need to address specifications pertaining to performance goals. Agencies may update RPPR format accordingly.
.215 “Never Contract with the Enemy” New requirement for International awards expected to exceed $50,000 in period of performance and in support of a contingency operation where U.S. Armed Forces are actively engaged in hostilities. Schools and central offices will be responsible for monitoring international awards to meet these restrictions.
.216 Prohibition on telecommunication equipment* Prohibition against purchasing telecommunication and video surveillance equipment, services or systems from specific vendors or purchasing equipment, services or systems which include such items as a substantial, essential or critical component. Procurement via iBuy will restrict purchases from prohibited vendors. Schools cannot contract directly with these vendors.
.320 Procurement Raises thresholds for: (1) Informal, small purchase under 10K (2) formal sealed bids- proposals over $250K (3) Non-Competitive sole source. Procurement will require appropriate bids/ documentation depending on type and amount of purchases.
.322 “Buy American” Implements a new preference for domestic procurement. This extends to subawards. Procurement will update policies and systems to identify vendors that are domestic.
.322 Pass-Through Entities (Subrecipients) The prime recipient must accept the subrecipient's federally approved rate. If no approved rate exists,  an agreed upon rate with the subrecipient or the 10% de minimis rate must be used. Also, the prime recipient is responsible for addressing only a subrecipient's audit findings that are specifically related to their subaward. Proposals must include subrecipients’ federally negotiated rate unless a lower rate is agreed upon.
NYU is responsible for addressing only audit finding(s) specific to NYU’s subaward and not any cross-cutting findings.
.340 Termination An award can be terminated if “an award no longer effectuates program goals or agency priorities”. Agencies can terminate awards for reasons other than the prior “for cause” language. Allows sponsors greater flexibility to end award support if it's not meeting program goals.
.344 Award Closeouts- extended Increases the number of days for recipients to submit closeout reports and liquidate all financial obligations from 90 to 120 days. NYU will follow current reporting submission timelines as dictated by NYU policies.This does not extend to subrecipients.
.458 Pre-Award Costs Only allowed for an initial budget period and can be extended to subrecipients. Pre Award costs outside of the initial budget period will not be allowed.
.461 Publication and Printing If costs are incurred during closeout, these costs must be charged to the final budget period of the award. Publication costs outside of the period of performance may still be allowable.

View the complete text of the Uniform Guidance revisions.