Subject: OMB "Super Circular"
From: Krista Pages <[email-masked]>
To: All ERD <[email-masked]>, All GBDU <[email-masked]>, All IEG <[email-masked]>, All IHD <[email-masked]>, All Social & Economic Policy Cambridge <[email-masked]>, All US Health <[email-masked]>, All Contract Operations <[email-masked]>, All Global Operations Control <[email-masked]>
Cc: Richard Small <[email-masked]>, Kevin O'Reilly <[email-masked]>, Jay Knott <[email-masked]>, Kathleen Flanagan <[email-masked]>, Brian Roemer <[email-masked]>
Date: Thu, 09 Oct 2014 15:32:18 +0000

Contracts Fast Facts:  OMB “Super Circular”

As part of an effort to reform and strengthen Federal grant making, the Office of Management and Budget (OMB) published new guidance on December 26, 2013 for Federal award programs -- OMB Uniform Guidance: Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, commonly referred to as the “Super Circular” or “Omni Circular”. While the Omni Circular took effect on December 26, 2013, federal agencies have six months to submit a draft of their implementing regulations to OMB; non-federal entities have until December 26, 2014, to comply fully.  The guidance finalizes OMB rules proposed in February 2013, and eliminates duplicate language found in eight OMB circulars (A-21, A-87, A-110, A-122, A-89, A-102, A-133, and A-50) that applied to federal awards. Prior to the new guidance, policies were often inconsistent across different types of entities.  The new circular streamlines these regulations into a single, comprehensive policy guide.  OMB’s goal is to help government agencies better administer grants and other types of financial assistance by decreasing the administrative burden for recipients and reducing the risk of waste, fraud and abuse.  The new guidance will go into effect on December 26, 2014.

What do these changes mean for Abt?  For the most part, there will be little change for Abt because most of the significant changes are to the current OMB Circulars A-133 (Audits State, Local, and Non-Profits), and A-120   (Educational Institutions).  For our U.S. Non-Profit clients and partners who are currently subject to the A-133 and A-120 regulations, the changes may impact how they comply with the regulations regarding financial controls, cost accounting, time-keeping and audits.

As a for-profit company, Abt - even when we do work under grants and cooperative agreements, continues to be regulated by the Federal Acquisition Regulations (Part 31) and other laws and regulations applicable to us.  However, whatever changes made by the OMB Super Circular that appear in our awards that do apply to our non-profit subrecipients and subcontractors will be passed down to them in our subawards and subcontracts as required by our awards.  For ease of reference, attached is a slide deck from a recent PSC meeting that sets out in detail the changes OMB has made.  As always, Abt’s Contract and Subcontract Administrators are available to answer any questions you may have regarding the OMB Supercircular.

Best Regards,

Krista

Krista L. Pages | Director of Contracts | Abt Associates

O: 301-347-5829| F: 301-828-9589 | www.abtassociates.com