EPA Implementation of Office of Management and Budget Regulatory Changes to 2 CFR 200
The Office of Management and Budget (OMB) published final guidance on August 13, 2020, and aside from two provisions published in RAIN-2020-G05, are effective November 12, 2020. EPA has updated the following policies, guidance and accompanying Recipient/Applicant Information Notices (RAIN) to implement these regulatory changes.
Grants Policy Issuance 18-02, Indirect Cost Policy and Guidance for Recipients of EPA Assistance Agreements and RAIN-2018-G02-R
EPA has revised the Indirect Cost Policy and Guidance and revised the RAIN to inform recipients and applicants of revisions from the Office of Management and Budget which revised 2 CFR Part 200 effective November 12, 2020, in part to streamline Indirect Cost (IDC) regulations to provide further flexibility for the use of the 10% de minimis indirect cost rate authorized in 2 CFR 200.414(f). EPA’s IDC Policy and Guidance has been updated to reflect these changes.
Grants Policy Issuance 16-01, EPA Subaward Policy and RAIN-2018-G03-R
EPA has revised the Subaward Policy and related Frequent Questions to conform to OMB’s revisions to the definition of Subrecipient in 2 CFR 200.1 and the regulatory coverage in 2 CFR 200.101, Applicability, which now provides that Federal agencies may receive subawards from pass-through entities when authorized by Federal statutes.
- GPI 16-01, PA Subaward Policy
- RAIN-2018-G03-R, Revisions to EPA's Conflict of Interest and Subaward Policy
Grants Policy Issuance 15-02, EPA's Financial Assistance Conflict of Interest (COI) Policy and RAIN-2018-G03-R
EPA has revised the COI Policy to update citations to 2 CFR Part 200.
- Grants Policy Issuance 15-02, EPA's Financial Assistance Conflict of Interest (COI) Policy
- RAIN-2018-G03-R, Revisions to EPA's Conflict of Interest and Subaward Policy
EPA Guidance on Participant Support Costs and RAIN-2018-G05-R1
EPA has revised the RAIN and issued final EPA Guidance on Participant Support Costs (PSC Guidance) to incorporate regulatory changes to 2 CFR 1500 on participant support costs (PSC). The final PSC Guidance provides information on how EPA interprets the definition of participant support costs at 2 CFR 1500.1.
- EPA Guidance on Participant Support Costs (see Related Resources at the bottom of the page)
- RAIN-2018-G05-R1
EPA General Terms and Conditions effective November 12, 2020 or later
EPA has updated multiple terms and conditions to implement OMB’s regulatory changes to 2 CFR 25, 2 CFR 170, 2 CFR 183, and 2 CFR 200 in the August 13, 2020 final guidance. Terms and Conditions are applicable to EPA Assistance Agreements and Monetary Amendments Issued on or after November 12, 2020.
EPA Office of Research and Development Research Terms and Conditions effective November 12, 2020 or later
EPA has updated multiple terms and conditions to implement OMB’s regulatory changes to 2 CFR 25, 2 CFR 170, 2 CFR 183, and 2 CFR 200 in the August 13, 2020 final guidance. Research Terms and Conditions are applicable to ORD Research grants and cooperative agreements issued on or after November 12, 2020.
Frequent Questions about Closeouts
EPA has updated frequent questions about closeouts to reflect the regulatory changes to 2 CFR 200.334, Closeout, regarding the number of days for recipients to submit closeout reports and liquidate all financial obligations from 90 days to 120 days after the end date of the period of performance.