REGULATORY & COMPLIANCE
Topics & Tools
The federal Office of Management and Budget (OMB) establishes policies and guidelines through its grants management circulars and government-wide common rules that are codified by each grant-making agency. Six OMB circulars provide the standard administrative requirements for the management of Federal funding, the cost principles for determining allowable and unallowable expenditures of Federal funding, and the requirements for auditing nonfederal parties' management of Federal funding.
Which Circulars Pertain to Grant Activity at JMU?
Although there are six grant circulars, only three apply to any type of entity. As an educational institution, JMU is covered by OMB A-21, A-110, and A-133.
- OMB Circular A-21, Cost Principles for Educational Institutions (05/10/2004) HTML or PDF (109 pages, 263 kb), Relocated to 2 CFR, Part 220 (30 pages, 384 kb)
- OMB Circular A-110, HTML, Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations (11/19/1993) (further amended 09/30/1999, Relocated to 2 CFR, Part 215 (32 pages, 243 kb))
- OMB Circular A-133, PDF, (34 pages, 173kb) Audits of States, Local Governments and Non-Profit Organizations (includes revisions published in the Federal Register 6/27/2003 and 06/26/2007)
-- June 2012 Compliance Supplement
-- March 2011 Compliance Supplement
-- June 2010 Compliance Supplement
-- March 2009 Compliance Supplement
-- March 2008 Compliance Supplement
-- Appendix A: Data Collection Form (Form SF-SAC)
The FAR was established to codify uniform policies for acquisition of supplies and services by executive agencies. It is issued and maintained jointly, pursuant to the OFPP Reauthorization Act, under the statutory authorities granted to the Secretary of Defense, Administrator of General Services and the Administrator, National Aeronautics and Space Administration. Statutory authorities to issue and revise the FAR have been delegated to the Procurement Executives in DOD, GSA and NASA. The official FAR appears in the Code of Federal Regulations at 48 CFR Chapter 1.
Agriculture (AGAR) FAR Supplement (from USDA)
Defense (DFAR) FAR Supplement (from DTIC)
Defense (DFAR) FAR Supplement (from USGI)
Department of Transportation TAR (from DOT)
NASA FAR Supplement (from NASA)
NASA FAR Supplement (from USGI)
DOE FAR (DEAR) Supplement
The Code of Federal Regulations (CFR) is the codification of the general and permanent rules published in the Federal Register by the executive departments and agencies of the Federal Government. It is divided into 50 titles that represent broad areas subject to Federal regulation. Each volume of the CFR is updated once each calendar year and is issued on a quarterly basis.
The Code of Federal Regulations (CFR)
The CAS are a result of concern for the pricing and accounting practices of defense contractors. There was no consistency within and between contractors’ cost accounting practices, making it difficult to conduct standard audits. CAS were designed to achieve uniformity and consistency in the measurement, assignment, and allocation of costs to Government contracts. The standards were based on examinations of common cost accounting practices throughout the industry.
The Cost Accounting Standards Board (CASB) has exclusive authority to make, promulgate, and amend cost accounting standards and interpretations designed to achieve uniformity and consistency in the cost accounting practices governing the measurement, assignment, and allocation of costs to contracts with the United States. The Board's regulations are codified at 48 CFR, Chapter 99. The standards are mandatory for use by all executive agencies and by contractors and subcontractors in estimating, accumulating, and reporting costs in connection with pricing and administration of, and settlement of disputes concerning, all negotiated prime contract and subcontract procurement with the United States in excess of $500,000.
CAS was extended to grants and cooperative agreements in Circular A-21 in 1996. The standards apply to all grants, contracts and cooperative agreements (collectively called sponsored agreements). The disclosure statement requirement applies to all institutions receiving $25 M (regardless of amounts of individual awards. James Madison University and other universities receiving federal funds are required to comply with the Cost Accounting Standards (CAS) set forth in Appendix A, OMB Circular A-21 (Cost Principles for Educational Institutions).
Cost Accounting Standards (PDF) - searchable
The Three Areas of Cost Accounting (48 CFR 9903.302-1)
Measurement of Cost involves the methods and techniques used in defining the components of cost, determining the basis of cost measurement, and establishing criteria for use of alternative cost measurement techniques. Examples of cost measurement are listed below:
The use of historical cost, market value, or present value;
The use of standard or actual cost; or
The designation of items of cost which must be included or excluded from tangible assets or pension cost.
Assignment of cost to cost accounting period refers to the method used in determining the amount of cost to be assigned to individual cost accounting periods. Examples are the requirements for use of accrual basis or cash basis accounting.
Allocation of cost to cost objectives refers to the method of determining direct and indirect allocation of cost. Examples of allocation issues are listed below:
The accumulation of costs;
The determination of whether to charge costs direct or indirect; or
The determination of the composition of cost pools and their allocation bases.