Required Policies & Procedures for Entities Managing Federal Grants!!

By: Rebecca Silva, CGMS

The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Title 2 of the Code of Federal Regulations – Grants and Agreements Part 200) updated in August 2020 established a minimum set of written policies and procedures. These requirements can be found under Subpart D – Post Federal Award Requirements and Subpart E – Cost Principles. These requirements apply to non-federal entities receiving federal awards as prime recipient or sub-recipient. 

There are eight basic policies and procedures required under the 2 CFR 200

  • Written Cash Management Procedure –200.302(b)(6) and 200.305
  • Written Cost Allowability Procedures –200.302(b)(7)
  • Written Conflicts of Interest Policy –200.318(c)
  • Written Procurement Procedures –200.318(a) and 200.319(d)
  • Written Method for Conducting Technical Evaluations of Proposals and Selecting Recipients –200.320(b)(2)(ii)
  • Written Travel Policy –200.475(a)
  • Procedures for Managing Equipment –200.313(d)
  • Employee Benefits –200.431

In addition, it is highly recommended to recipients and sub recipients’ entities to revise yearly all their written policies and procedures to ensure compliance will all the applicable regulations and federal guidance. Recipients and sub recipients’ entities with written policies and procedures are strong in internal controls, which is the basis for accountability and sets the path to increase funding sources within the entity.  

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If you have any questions on this and any other Federal Grants related matter, please do not hesitate to contact our Federal Grants Advisory Services Team 787-425-0500 or email us