Uniform guidance 2 cfr 2004/8/2023 HUD is finalizing its conflict-of-interest policy, but entities are still expected to use the policies developed under the various Community Planning and Development (CPD) program-specific regulations. Regulations at 2 CFR 200.112 require HUD to establish conflict of interest policies for Federal awards and require non-Federal entities to disclose in writing any potential conflict of interest to HUD or a pass-through entity in accordance with HUD’s policy. For example, an affiliate or instrumentality of a PHA may be a subrecipient of funds, such as CDBG or HOME, that were obligated on or after Decemand are subject to Uniform Guidance. This may impact PHAs other than as direct recipients of a federal award. (ii) the Federal awards were made on or after December 26, 2014. (i) the terms of a Federal award made prior to Decemstate that the award will be subject to regulations as may be amended unless B(i) below applies, 24 CFR part 85 (2013 edition) or as provided by the terms of the Federal award if the Federal awards were made prior to December 26, 2014. Federal awards will be governed by the regulations in effect and codified in:Ī. As noted in the Integrity Bulletin, "egulations are in transition between grants issued before Decem(when 2 CFR Part 200 went into effect), and those issued later."Īdditionally, it is important to note that outside of procurement, the effective date of the Uniform Guidance is December 26, 2014. If a PHA chooses to delay implementation of the procurement standards in the Uniform Guidance and use the prior procurement standards during this grace period, the PHA must document this decision in its internal procurement policies PHAs should ensure that they have taken this necessary step, if applicable. For example, a PHA with a fiscal year that starts on July 1 could take advantage of such grace period and delay implementation of the procurement standards in the Uniform Guidance until June 30, 2017. §200.110(a) provides public housing agencies (PHAs) a grace period of two additional fiscal years after Decemto implement the procurement standards in 2 C.F.R. Part 200, PHAs should take note of these developments. While as of the writing of this article, the Office of Public and Indian Housing has not issued a notice providing additional transition and implementation guidance for 2 C.F.R. HUD’s Office of Inspector General issued an Integrity Bulletin titled 7 Keys to Handling Conflicts of Interest (Integrity Bulletin).HUD’s Office of Community Planning and Development issued Notice CPD-16-04 and.HUD published conforming changes to its program regulations.the Office of Management and Budget published corrections and amendments in the Federal Register.Department of Housing and Urban Development (HUD) issued Notice SD-2015-01 Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), became effective on December 26, 2014: Since the joint interim final rule, 2 C.F.R.
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