The Office of Management and Budget (OMB) streamlined the federal government’s guidance on administrative requirements, cost principles, and audit requirements for federal awards by creating the Omni Circular—also known as the Uniform Guidance—2 CFR 200. The goal of the reform was to (1) streamline guidance for federal awards to ease administrative burden and (2) strengthen oversight over federal funds to reduce waste, fraud, and abuse. These regulations came into effect on December 26, 2014. The Federal Highway Administration (FHWA) issued guidance on significant changes in the various sections of the Uniform Guidance affecting FHWA business processes.
Also in 2014, several state transportation agencies participated in a FHWA National Process Review on Subpart B of State Planning and Research (SPR), specifically seeking to discover how they were complying with requirements of 23 CFR 420. After concluding that there were no uniform metrics for successful implementation of state DOT research programs and general grant administrative procedures, the Process Review Team recommended development of (1) processes for monitoring unexpended federal funds beyond the work program time frame; (2) implementation of processes that allow follow up on audit findings; (3) documentation of monitoring procedures; and (4) review of department practices related to federal procurement law. It is expected that each state transportation research program would develop their own individual procedures for compliance, but no national discussion of successful practices occurred. State transportation agencies are, however, expected to revise their processes accordingly to ensure compliance.
The objective of this research was to produce comprehensive guidance on successful practices for complying with 2 CFR 200 for state transportation research programs using federal aid. The guidance addresses implementation challenges identified by transportation agency staff and the vendors and/or subrecipients and provides potential alternatives. These challenges include—but are not limited to—implementing Uniform Guidance requirements at both the program and project levels related to: performance period end dates; project closeout; risk assessment; cost sharing; procurement; indirect cost rates; reporting; and performance measurement.