Procurement Manual

Appendix C - Uniform Guidance or 2 CFR 200 Definitions - Federally Funded Sponsored Projects 

Compliance with all relevant policies and regulations is the responsibility of all employees engaged in procurement. Office of Management and Budget (OMB) issued Uniform Administrative Requirements, Cost Principles, and Audit Requirements (Uniform Guidance or 2 CFR 200) for federal awards. The Uniform Guidance streamlines and supersedes guidance previously contained in eight separate OMB Circulars.  Included in the new guidance are uniform administrative requirements (pre and post-award), cost principles, audit requirements, and definitions.

GW has moved forward to update its policies and procedures with the exception of the Procurement Policy for which the university accepted the one year extension provided. The new Procurement guidelines took effect for GW on July 1, 2018.

Important to note for Sponsored Projects, the Uniform Guidance supersedes OMB Circulars A-110, A-21, and A-133 Below find four important definitions: Federal award, contract, contractor and subaward.

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Below find four important definitions: Federal award, contract, contractor and subaward. For more information, read GW’s Sponsored Projects Handbook.

200.38 Federal award

Federal award has the meaning, depending on the context, in either paragraph (A) or (B) of this section:

(A)(1) The Federal financial assistance that a non-Federal entity receives directly from a Federal awarding agency or indirectly from a pass through entity, as described in 200.101 Applicability; or

(A)(2) The cost reimbursement contract under the Federal Acquisition Regulations that a non-Federal entity receives directly from a Federal awarding agency or indirectly from a pass through entity, as described in 200.101 Applicability

(B) The instrument setting forth the terms and conditions.  The instrument is the grant agreement, cooperative agreement, other agreement for assistance as defined in paragraph (B) of §200.40 Federal financial assistance, or the cost reimbursement contract awarded under the Federal Acquisition Regulations. 

(C) Federal award does not include other contracts that a Federal agency uses to buy goods or services from a contractor or a contract to operate federal government owned, contractor operated facilities (GOCO’s). 

200.22 Contract

Contract means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award.  The term as used in this part does not include a legal instrument, even if the non-Federal entity considers it a contract, when the substance of the transaction meets the definitions of a Federal award or subaward.

200.23 Contractor

An entity that receives a contract as defined in 200.22.

200.23 Contractor

An entity that receives a contract as defined in 200.22.

200.92 Subaward

An award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a Federal award received by the pass through entity.  It does not included payment to a contract or payments to an individual that is a beneficiary of a Federal program.  A subaward may be provided through any form of legal agreement, including an agreement that the pass through entity considers a contract.