Policy Memo (359.55 KB)
| DATE: | October 30, 2015 | |
| POLICY MEMO: | SP02 CACFP02 SFSP02-2016 | |
| SUBJECT: | Questions and Answers on the Transition to and Implementation of 2 CFR Part 200 | |
| TO: | Regional Directors Special Nutrition Programs All Regions |
State Directors Child Nutrition Programs All States |
Federal agencies including Food and Nutrition Service (FNS), state agencies, and child nutrition program operators are currently transitioning from former federal grants management rules in 7 CFR Parts 3016, 3019, and 3052; and the cost principles in 2 CFR Parts 220 (A-21), 225 (A-87), and 230 (A-122) to the implementation of new rules at 2 CFR Part 200, commonly referred to as the Super-Circular. These rules, first published on Dec. 26, 2013, directed federal agencies to “implement the policies and procedures applicable to federal awards by promulgating a regulation to be effective [no later than] Dec. 26, 2014, unless different provisions are required by statute or are approved by the Office of Management and Budget (OMB).”
FNS has received many questions related to implementation of 2 CFR Part 200 and understands that changes to financial and procurement systems are costly and require time to develop and implement. Therefore, FNS will work with state agencies during this transition period and will seek to answer questions and provide guidance as needed. A list of common questions and answers received to date is attached.
State agencies are reminded to distribute this memorandum to program operators immediately. Program operators should contact their state agency for additional information, as needed. State agencies with questions concerning this guidance may contact the appropriate FNS regional office.
Sarah E. Smith Holmes
Director
Program Monitoring and Operational Support Division
Child Nutrition Programs