Notes on 2 CFR 600

2 CFR 600 is DOS's regulation adopting and augmenting 2 CFR 200 (links are to eCFR).

As noted in About 2 CFR 200, each federal awarding agency is required to implement the OMB's uniform guidance in its own regulation. In general, agencies have taken the approach of adopting the text of 2 CFR 200 by reference in their adopting regulation and modifying and/or augmenting the uniform guidance in accordance with each agency's statutory requirements. DOS takes this approach with 2 CFR 600.

Here's what else 2 CFR 600 does.

§ 600.101 Applicability.

  • adopts and gives regulatory effect to 2 CFR 200, with exceptions as follows:
    • Subparts A through E of the uniform guidance (including the cost principles) applicable to foreign organizations; but
    • 48 CFR parts 30 and 31 (FAR cost accounting standards and contract cost principles) take precedence over Subpart E (cost principles) for recipients that are US or foreign for-profit entities (except when DOS determines doing so would be inconsistent with international obligations etc.). See also About the FAR (Federal Acquisition Regulation).

§ 600.205 Federal awarding agency review of risk posed by applicants.

  • requires DOS to use 2 CFR 200.205 (does this mean anything?).

§ 600.315 Intangible property.

  • allows DOS to charge the requester fees for data that is obtained solely in response to a FOIA request.

§ 600.407 Prior written approval (prior approval).

  • adds the requirement for the NFE to seek DOS approval for indirect or special or unusual costs prior to incurring such costs, when DOS is the cognizant agency for indirect costs.

22 CFR 135 and 22 CFR 145 were removed from the CFR at this same time (79 FR 76019 — you'll need to scroll to 76019), but not in the substance of 2 CFR 600 itself.

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