Monday, November 27, 2006


OMB, CFR, Title 2 and More Exciting Nonprofit Stuff
by Pam Ashlund

For two decades nonprofits have been guided by three OMB circulars: OMB A-133, A-122, and A-110. As of September, 06, two of these three fixtures of the nonprofit world are being phased out and then coming back to life in the Code of Federal Regulations (CFR).

Title 2 of the Code of Federal Regulations–(A-122 becomes Part 230 and A-110 becomes Part 215) to be exact. The rules won't change as far as I can figure. Only the names have been changed. Apparently there were some contradictions between the OMB's and the CFR's. The change will streamline and thereby resolve the conflicts.

Sounds like implementation won't happen until later in 2007 and nonprofits won't really have to comply until government funding sources update their contract language; but it is coming soon.

FYI, I wouldn't worry about compliance or implementation, since we're already bound to follow these OMB circulars.

Read the actual text in the Federal Register, 8/31/2005 (Vol. 70, # 168) or the text of the new and improved Title 2 (in pdf format).

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