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Questions and Answers on the Transition to and Implementation of 2 CFR Part 200

EO Guidance Document #
FNS Document #
SP02 CACFP02 SFSP02-2016
Resource type
Policy Memos
Guidance Documents
Resource Materials
PDF Icon Policy Memo (359.55 KB)
DATE: October 30, 2015
SUBJECT: Questions and Answers on the Transition to and Implementation of 2 CFR Part 200
TO: Regional Directors
Special Nutrition Programs
All Regions
State Directors
Child Nutrition Programs
All States

Federal agencies including Food and Nutrition Service (FNS), state agencies, and child nutrition program operators are currently transitioning from former federal grants management rules in 7 CFR Parts 3016, 3019, and 3052; and the cost principles in 2 CFR Parts 220 (A-21), 225 (A-87), and 230 (A-122) to the implementation of new rules at 2 CFR Part 200, commonly referred to as the Super-Circular. These rules, first published on Dec. 26, 2013, directed federal agencies to “implement the policies and procedures applicable to federal awards by promulgating a regulation to be effective [no later than] Dec. 26, 2014, unless different provisions are required by statute or are approved by the Office of Management and Budget (OMB).”

FNS has received many questions related to implementation of 2 CFR Part 200 and understands that changes to financial and procurement systems are costly and require time to develop and implement. Therefore, FNS will work with state agencies during this transition period and will seek to answer questions and provide guidance as needed. A list of common questions and answers received to date is attached.

State agencies are reminded to distribute this memorandum to program operators immediately. Program operators should contact their state agency for additional information, as needed. State agencies with questions concerning this guidance may contact the appropriate FNS regional office.

Sarah E. Smith Holmes
Program Monitoring and Operational Support Division
Child Nutrition Programs


Page updated: April 07, 2023

The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.