Regulations, Policies, and Procedures
Federal Agency Implementation of OMB Circular A-110
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Agency |
Issuance Date |
Effective Date |
CFR |
Revisions/Additions/Notes |
Comparison to A-110 as Issued |
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Agriculture |
Aug. 24, 1995 |
Aug. 24, 1995 |
7 CFR 3019 |
On February 17, 1998 (63 FR 7734), revised to include entitlement programs in implementation; however, this remains an interim final rule. |
Implemented nearly verbatim, but also included clauses for awards to commercial concerns |
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Commerce |
Sept. 4, 1998 |
Oct. 1, 1998 |
15 CFR 14 |
Very little change, retained prior approval for budget revisions |
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Corporation for National and Community Service |
Mar. 10, 1995 |
Mar. 10, 1995 (final) |
45 CFR 2543 |
Implemented verbatim |
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DOD |
Mar. 12, 1998 |
Apr. 13, 1998 (final) |
32 CFR 32 |
Part of DOD Grant and Agreement regulations; encourages DOD grants officers to consolidate certification requirements; retained agency approval for one-time no cost extensions; additional prior approval for rebudgeting actions on awards in excess of $100,000 where rebudgeting will be 10% of budget and for transfer of funds between direct and indirect cost categories. |
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ED |
July 6, 1994 |
Oct. 1, 1994 (final) |
34 CFR 74, 77 |
On November 17, 1994 (59 FR 50589, further costing changes were included in the ED implementation; further amendments were made on September 6, 1995 (60 FR 46491) |
Limited indirect cost reimbursement to 8% for training grants; prohibited use of difference between actual indirect cost rates and 8% MTDC as cost sharing or matching |
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Energy |
Oct. 21, 1994 |
Nov. 21, 1994 |
10 CFR 600 |
Very few changes; allows unrecovered IDC to be used as cost sharing |
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EPA |
Feb. 15, 1996 |
Mar. 18, 1996 |
40 CFR 30, 33 |
Very few changes; inclusion of Hotel and Motel Fire Safety Act regulations (travel funds impact) and limitation on allowability of preaward costs as automatic institutional approval for research grants |
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GSA |
Sept. 15, 1994 |
Sept. 15, 1994 (final) |
49 CFR 105-72 |
Adopted verbatim |
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HHS |
Aug. 25, 1994 |
Aug. 25, 1994 |
45 CFR 45 |
Issued as final with some non-substantive changes from interim status on Mar. 22, 1996 (61 FR 17743) |
Very few changes; remember that HHS agencies implemented further, such as NIH in its 12/23/94 NIH guide |
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Agency |
Issuance Date |
Effective Date |
CFR |
Revisions/Additions/Notes |
Comparison to A-110 as Issued |
|
HUD |
Sept. 13, 1994 |
Oct. 13, 1994 |
24 CFR 84 |
Subpart E as previously issued was adopted as final on June 20, 1995 (60 FR 32102) |
No significant changes |
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Interior |
Aug. 26, 1994 |
Aug. 26, 1994 |
43 CFR 12 |
Made A-110 applicable to agreements with commercial organizations; significantly limited prior approval waivers |
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Justice |
July 26, 1995 |
Sept., 26, 1995 (final) |
28 CFR 70 |
Corrections to the final rule were issued on November 24, 1995 (60 FR 57931) |
Only one significant change; equipment inventories required every year instead of A-110 requirement of every two years |
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Labor |
July 17, 1994 |
July 27, 1994 (final) |
29 CFR 95 |
No significant changes; incorporated commercial organizations and foreign governments into applicability; written approval required for moving funds from indirect to direct costs or vice-versa; limited use of one-time, no-cost extensions |
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NASA |
Oct. 19, 2000 |
Oct. 19, 2000 |
14 CFR 1260 |
No substantive revisions |
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National Archives and Records Administration |
Oct. 16, 1995 |
Nov. 15, 1995 (final) |
36 CFR 1210 |
Interim rule was finalized on February 13, 1996 (61 FR 566) |
Adopted nearly verbatim |
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NEH |
November 2001 |
November, 2001 |
N/A |
Expanded authorities apply to all NEH grants; institutions must have a written organizational prior approval system, specific accounting records source documents |
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NSF |
Apr. 25, 1994 |
May 2, 1994 (final) |
N/A |
Very little change, but did make applicable to commercial organizations; allowed unrecovered indirect costs to be used as cost sharing some limitation of prior approval |
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State |
Apr. 20, 1994 |
Oct. 1, 1994 (final) |
22 CFR 145 |
No substantive revisions |
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Transportation |
Apr. 4, 1994 |
Apr. 4, 1994 |
49 CFR 19 |
No substantive revisions |
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United States Information Agency |
Aug. 3, 1994 |
Aug. 3, 1994 (interim final) |
22 CFR 513 |
Interim rule issued as final on November 30, 1994 (59 FR 61272) |
Adopted verbatim |
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NOTE: As Federal statues are enacted or revised, certain changes are automatic to A-110. For example, on August 29, 1997 (62 FR 45937), an interim final rule was issued to A-110 to implement the provisions of the 6/24/97 revision of OMB circular A-133, which combined the former A-133 and A-128 audit circulars. Another statue change resulted in the threshold for the imposition of the Central Work Hours and Safety Standards Act to be effective at the $100,000 grant award level. Likewise, other changes also have become or will become automatic, such as the redefinition of "simplified acquisition" (formerly called small purchase) threshold to $100,000 and the requirement for all federal payments to become electronic as of 1/1/99. |
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June 2002
From NACUBO and NCURA's "A Guide to Managing Federal Grants for Colleges and Universities," Paragraph 310.


