A Whitepaper from Redstone Government Consulting

Federal Acquisition Regulations (FAR) is structured significantly differently than OMB Guidance 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (i.e., Grants and Cooperative Agreement). The FAR is structured into two main sections:

  • Instructions to Contracting Officers, Parts 1 through 51 and
  • Contractual Requirements for contractors, Part 52 Contract Clauses.

Some FAR contract clauses do require the contractor to comply with contracting officer instructional parts – for example, FAR 52.216-7, Allowable Cost and Payment, clause provides the “amounts determined to be allowable by the Contracting Officer in accordance with Federal Acquisition Regulation (FAR) subpart 31.2” are to be reimbursed to the contractor, thus requiring contractors to comply with FAR subpart 31.2. There are other FAR contract clauses that specifically require a higher-tier contractor to flow down the same contractual language to its subcontractors. For example, FAR 52.215-12, Subcontractor Certified Cost or Pricing Data, which in (c) requires the higher-tier contractor to include the substance of this clause, including this paragraph (c) in its subcontracts.

2 CFR 200 is not structured the same as the FAR and requires an in-depth understanding of the entire 2 CFR 200 to determine the contractual requirements applicable to your organization, as well as those that you must flow down to lower-level organizations supporting awards. For the most part, Federal Awards supporting Federal programs simply incorporate the entire 2 CFR 200 by reference.

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