Hogan Lovells Government Contracts Associate Ogechi Achuko contributed to this post.

On 17 September 2015, USAID finalized its regulatory supplement to the OMB “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards”, often referred to as the Uniform Guidance.  USAID’s regulations largely are consistent with the OMB Uniform Guidance at 2 CFR part 200, with some revised and complementary provisions.  Notably, these provisions incorporate USAID’s policy to apply different standards to foreign grantees, and to apply the Federal Acquisition Regulation (FAR) cost principles to for-profit grantees. Many grantees—particularly those with a large footprint abroad—will continue to face some classic compliance questions under the new rules.

A summary of key provisions follows.