In a previous blog, we explored whether DCAA compliant software exists. But what about 2 CFR Part 200 compliant ERP software? Let’s start off by clarifying that ERP software alone does not ensure compliance, no matter if it’s for DCAA audits, 2 CF Part 200, or otherwise. However, ERP software like Unanet can act as a supplement to an organization’s best practices and procedures, making the path to compliance easier.
What Is 2 CFR Part 200?
The purpose of 2 CFR part 200 is to streamline the Federal government’s guidance on administrative requirements, cost principles, and audit requirements to more effectively focus Federal resources on improving performance and outcomes, while ensuring the financial integrity of taxpayer dollars in partnership with non-Federal stakeholders. The uniform guidance supersedes, consolidates, and streamlines requirements from eight OMB Circulars:
- A-21: Cost Principles for Educational Institutions
- A-87: Cost Principles for State, Local and Indian Tribal Governments
- A-89: Catalog of Federal Domestic Assistance
- A-102: Grants and Cooperative Agreements With State and Local Governments
- A-110: Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations
- A-122: Cost Principles for Non-Profit Organizations
- A-133: Audits of States, Local Governments, and Non-Profit Organizations
- The guidance in OMB Circular A-50, Audit Follow-up, on Single Audit Act follow-up
As you can see, the new super circular re-laces all of the old OMB circulars that served as the procurement regulations for Ed institutions, state & local governments, tribal governments, and non-profits that did not come under FAR. Like the FAR cost principles, compliance is a matter of an organization’s policies, procedures, and practices and NOT their software tools. It is no more possible for any software tool to be “compliant” with the cost principles of the super circular than to be compliant with the FAR cost principles. The circular is about how an organization does their cost accounting, not what tool they use.
The problem is the use of the term “system” in the solicitation provision. In the usage, the term refers to the organization’s policies, procedures, and practices, not their software. Keep this in mind when reviewing compliance requirements.
Unanet Can Supplement Your Organization’s 2 CFR Part 200 Best Practices
While 2 CFR Part 200 compliant software may not exist, software such as Unanet, that is purpose-built for government contractors, can significantly help organizations achieve and maintain compliance. Unanet customers have also been able to meet other compliance requirements, such as those enforced by the DCAA. Unanet software has been reviewed by DCAA auditors at more than one thousand customer sites and, along with the customer policies and procedures, approved as supporting DCAA requirements.
If you’d like to learn more about the role ERP software can play in compliance, download our white paper, "SF1408 Compliance - Accounting and Timekeeping for Government Contractors" or register for a demo!