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Tuesday, January 14, 2014

30,000 feet assessment of OMB Uniform Administrative Requirements, Cost Principles and Audit Requirements as applied by USAID Implementers

Location:  2 C.F.R. 200

Consolidates and Replaces:
This final guidance supersedes and streamlines requirements from OMB Circulars A–21, A–87, A–110, and A– 122 (which have been placed in OMB guidance); Circulars A–89, A–102, and A–133; and the guidance in Circular A–50 on Single Audit Act follow-up.

Overall Impression: Much more detailed guidance on responsibilities of the Recipient as the Pass-Through, i.e. issuing sub-grants, as well as the Recipient as the Buyer, i.e. conducting procurement under Assistance Awards.

This regulation specifically outlines the Recipient’s responsibility and requires Recipients to follow specific guidelines in regard to subawardees in a much more detailed manner than any other regulation. It also establishes and outlines very detailed and specific rules for engaging vendors, now called uniformly “contractors”, under the revised and expanded Procurement Guidelines.

Effective Date: December 26, 2013 (to be reviewed every 5 years)

But - USAID has 12 months from the effective date to implement, codify and update agency specific guidance, i.e. revise 22 C.F.R 226 to comply with these new regulations.

However, Cost Principles are effective as of December 26, 2013 and do not require USAID’s involvement. Therefore the revised Cost Principles apply immediately to all new incremental funding released after and all new awards signed after December 26, 2013.

Some quick (and in no way comprehensive) highlights as they apply to USAID implementers:

Thursday, January 2, 2014

Payment of Post Differential for Third Country Nationals - USAID Contracts & Assistance

Situation: Third Country Nationals (TCN) are approved to receive expatriate allowances on the same basis as US nationals. Post Differential, Danger Pay, COLA etc.

Issue: AIDAR 752.7028 says that “Sick or vacation leave taken at or away from the post of assignment will not interrupt the continuity of the assignment or require a discontinuance of such post differential payments, provided such leave is not taken within the United States or the territories of the United States”.

Question: TCNs do not go on vacation to the US (unless they have not yet been to Disney Land), they go home, to their Third Country. Does their Post Differential Interrupt or Not?