To clarify requirements regarding responsibility for audit findings, OMB proposes a revision to 2 CFR Requirements for pass-through entities to clarify that pass-through entities (PTE) are responsible for addressing only a subrecipient’s audit findings that are specifically related to their subaward. For example, a PTE is not required to address all of the subrecipient’s audit findings. In addition, the PTE may rely on the subrecipient’s auditors and cognizant agency’s oversight for routine audit follow-up and management decisions. These changes reduce the burden for PTEs by allowing a PTE to rely on the cognizant agency to address a subrecipient’s entity-wide issues.
OMB also proposes to clarify the timing of submission of the disclosure statement (DS-2), which is only required for universities that meet certain thresholds as defined in 48 CFR -1(f). This revision reduces burden for universities while maintaining the requirement for universities to implement policies in compliance with 2 CFR. OMB seeks comments on whether the proposed revisions clarify 2 CFR requirements and reduce burden for PTEs and universities.
C. Response to Frequently Asked Questions Related to the Prior Release of 2 CFR
In , OMB developed and posted Frequently Asked Questions (FAQs) on the Chief Financial Officers Council website in response to stakeholder requests for clarification on the first publication of 2 CFR ( Due to the volume of questions related to these topics, OMB proposes clarifying the following: The meaning of the words “must” and “may” as they pertain to requirements; the effective date of 2 CFR; applicability and documentation requirements when a non-Federal entity elects to charge the de minimus indirect cost rate of modified total direct costs (MTDC); pass-through entity responsibilities related to indirect cost rates and audits; and applicability of 2 CFR to FAR based contracts.