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When the Cochiti Pueblo of New Mexico objected to the development of hydropower at the Cochiti Dam, Hobbs Straus helped the Tribe secure legislation blocking its development (1990).

General Memorandum 15-085

General Memorandum 15-085
Revised Rules for Managing Federal Funds at 2 CFR Part 200 – Final Provision Regarding Procurement Fast Approaching

In December 2013 the Office of Management and Budget (OMB) published new, final guidance that addresses administrative requirements, cost principles, procurement, contracting, and audit requirements for recipients of federal financial assistance. (See our General Memorandum 14-004 of January 13, 2014.) The revised regulations are codified at 2 CFR Part 200. The deadline for implementing one key piece of the new regulations – dealing with procurement – was extended for one fiscal year and that deadline is now December 31, 2015.

In December 2014, OMB, together with various federal award-making agencies, including the Department of Housing and Urban Development (HUD), published a joint interim final rule implementing the final guidance for 2 CFR Part 200 at 79 FEDERAL REGISTER 75871, "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards." The final rule begins on page 75880 of the FEDERAL REGISTER notice, and is available at http://federalregister.gov/r/0605-AA34.

The purpose of the revised regulations is to streamline the federal government's guidance, administrative requirements, and procurement regulations by consolidating the requirements from eight OMB Circulars and other regulations into a single regulation at 2 CFR Part 200. The new standards are government-wide, affecting procurement and contracting for many federal agencies, including HUD. The revised regulations will affect tribal governments and tribal entities such as Tribally Designated Housing Entities that receive federal awards. It is important for recipients of federal awards to review and properly revise their procedures as needed to comply with the new regulations.

The uniform guidance was applicable to federal agencies effective December 26, 2013. Federal agencies adopted 2 CFR Part 200 as a requirement for federal financial assistance programs by the interim final rule published December 19, 2014. The new regulations became applicable to non-federal entities effective December 26, 2014, with one exception: 2 CFR Part §200.110(a) was revised to allow a grace period for one full fiscal year for implementation of the new procurement standards contained in the rule. The decision to use the grace period must be documented within the non-federal entities' internal procurement policies. Important deadlines for revising policies are:

• For non-federal entities on a fiscal calendar year that have not yet revised their policies, the deadline for revision is December 31, 2015.
• For non-federal entities following the federal government's fiscal year, the deadline is the end of September 2016.
• For non-federal entities that follow a different fiscal year, they would need to revise their policies once a full fiscal year has passed following December 26, 2014.

If we may be of assistance regarding the revised federal regulations at 2 CFR Part 200, and in particular to those non-federal entities on a fiscal calendar year that must meet the procurement requirements effective no later than December 31, 2015, please let us know.

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Inquiries may be directed to:
Ed Clay Goodman (egoodman@hobbsstraus.com)
Geoff Strommer (gstrommer@hobbsstraus.com)

Available Documents for Download ( any referenced attachments are included in download )


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