--- name: uniform-guidance-check description: >- Checks a purchase paid for by a federal award against 2 CFR part 200, the Uniform Guidance. Looks for the pass-through entity and subrecipient relationship, documented procurement procedures, conflict of interest standards, full and open competition, cost or price analysis, and the Appendix II contract provisions including Byrd anti-lobbying and suspension and debarment. --- # Uniform Guidance (2 CFR 200) check ## Who this applies to 2 CFR part 200 binds a state, local government, Indian Tribe, institution of higher education or non-profit that carries out a federal award as a recipient or subrecipient, and it flows down every tier of subaward until a document says it stops (200.101(b)(1)). "Local government" expressly includes a local public authority, which is how an airport authority is caught. The trigger is federal award money. If no federal award funds this transaction, say so in one sentence and stop. ## The regulation text is in this Skill's own folder The rules this check cites are bundled under `reference/`, so quote the rule itself rather than only naming it. The files are whole subparts and parts, which is why you should `grep` for the section number you want and read the region around the hit rather than reading a file from end to end. Every file opens with a header naming its publisher, the address it came from and which edition this copy is. Where the bundled copy and the publisher's current version differ, the publisher's version governs and this copy is stale, so say that rather than presenting the bundled wording as necessarily current. | File under `reference/` | What it settles | | ---------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------- | | `2-cfr-200-procurement-standards-317-to-327.md` | the eleven procurement sections, which are the heart of this check | | `2-cfr-200-appendix-ii-contract-provisions.md` | the clause list every federally funded contract must carry, with thresholds | | `2-cfr-200-subpart-a-definitions.md` | 200.1, including contractor as against subrecipient and the thresholds | | `2-cfr-200-subpart-b-general-provisions.md` | applicability, exceptions and the flow-down rule at 200.101 | | `2-cfr-200-subpart-c-pre-federal-award.md` | what the federal award itself must contain | | `2-cfr-200-subpart-d-post-federal-award.md` | everything outside 200.317 to 200.327, including subrecipient monitoring | | `2-cfr-1201-dot-adoption-and-317-reversal.md` | that DOT money removes the state exception at 200.317 | | `2-cfr-25-unique-entity-identifier-and-sam.md` | the UEI and SAM registration award term | | `2-cfr-180-nonprocurement-debarment.md` | the exclusion checks Appendix II(H) points at | | `2-cfr-184-buy-america-preferences.md` | the Build America, Buy America preference for infrastructure | | `2-cfr-170-ffata-subaward-reporting.md`, `2-cfr-175-trafficking-in-persons.md`, `2-cfr-182-drug-free-workplace.md`, `2-cfr-183-never-contract-with-the-enemy.md` | the other government-wide award terms | Subparts E and F, the cost principles and the single audit, are not bundled. A question that turns on allowability of a cost or on audit thresholds is one to name as unchecked. ## Do this 1. Read the whole document. Identify the buyer, the federal award (FAIN, Assistance Listing number, awarding agency, pass-through entity), and the estimated value. 2. Check these points and report each as found, not found, or not applicable, with the paragraph. Before you report a point, grep the bundled file named beside it, because the wording of the rule is what decides whether the document satisfies it: - The buyer's documented procurement procedures and written standards of conduct on conflicts of interest, reaching board members, are referenced (200.318). - Full and open competition is stated, and whoever wrote the specification is excluded from competing (200.319). - The procurement method named is one of the three types 200.320 now describes, informal, formal or noncompetitive, rather than the five the pre-2024 text described. Read 200.320 in `2-cfr-200-procurement-standards-317-to-327.md` before deciding, since this is where a document written against the old text shows itself. - A cost or price analysis is required above the simplified acquisition threshold, including on modifications (200.324). - The Appendix II clauses appear at their thresholds. Take the thresholds from `2-cfr-200-appendix-ii-contract-provisions.md` item by item rather than from memory, and report each item separately, because a contract usually carries some and not others. - The document does not claim the 200.317 state exemption while the buyer is a subrecipient of a State; a subrecipient follows 200.318 through 200.327 in full. - For Department of Transportation money, 2 CFR 1201.317 rather than 200.317 governs, so an FAA, FTA or FHWA funded purchase by a state gets no state exception. 3. Suggest an edit only where the fix is wording inside this document for one of the points above, such as a missing Appendix II clause at a stated value; otherwise describe the gap in one line. 4. End with one short paragraph headed "Not checked", naming what this check did not cover and why, in plain sentences. ## Sources Every rule quoted above is carried in the bundled `reference/` folder, so this check does not need to fetch anything. These are the editions it was built from, and the place to confirm a point that matters: - **2 CFR Part 200 Subparts A to D, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards** https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200 eCFR as amended through 2026-09-01 - **Appendix II to 2 CFR Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards** https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/appendix-Appendix%20II%20to%20Part%20200 eCFR as amended through 2026-09-01 - **2 CFR Part 1201, Department of Transportation adoption, where 1201.317 reverses 200.317** https://www.ecfr.gov/current/title-2/subtitle-B/chapter-XII/part-1201 eCFR as amended through 2026-09-01 - **2 CFR Parts 25, 170, 175, 180, 182, 183 and 184, the government-wide award terms** https://www.ecfr.gov/current/title-2/subtitle-A/chapter-I eCFR as amended through 2026-09-01 - **2 CFR Part 200 Subparts E and F, cost principles and audit requirements, which are named rather than carried here** https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200 consult the publisher - **OMB Compliance Supplement 2025, which is named rather than carried here** https://www.federalregister.gov/documents/search?conditions%5Bterm%5D=90+FR+54400 90 FR 54400