The Super Circular: What the New Rules Mean for Recipients of Federal Grant Awards

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As 2013 came to a close, the Office of Management and Budget (OMB) issued the long-awaited final rule to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, more commonly known as the “Super Circular.” Among other things, this rule streamlines eight Federal regulations (including OMB Circulars A-110, A-122, and A-133) into a single, comprehensive policy guide and affords the Federal government the ability to better administer the $600 billion awarded annually for grants, cooperative agreements, and other types of financial assistance. While the Super Circular does not entirely change the eight Federal regulations from which it is derived, it does include some noteworthy changes that will have important implications for all nonprofit recipients of, and applicants for, Federal grants and cooperative agreements.

Speaker and Presenter Information

Dismas Locaria

Dismas Locaria is a partner in Venable LLP. He has represented clients before various Federal agencies, including the Department of Defense, General Services Administration, Department of Homeland Security, Small Business Administration, Environmental Protection Agency, and others. Mr. Locaria has developed several specialty areas, including representing clients in suspension and debarment proceedings, as well as performing internal investigations, which has included assistance and representation for such clients with disclosures to federal officials regarding the findings of such investigations and working with the client to determine and implement compliance enhancements and improvements.

Melanie Jones Totman

Melanie Jones Totman is an associate with Venable’s Government Contracts team where she provides clients with legal advice related to both federal and state procurement law, including complex compliance matters under the Federal Acquisition Regulation, the Office of Management and Budget Circulars, and various state procurement laws and grant regulations. She generally advises clients on small business, False Claims Act, and mandatory disclosure issues. Ms. Totman has broad experience in the defense of audits by various Offices of Inspector General, federal agencies, and the Defense Contract Audit Agency. She represents clients in a variety of bid protests before the United States Government Accountability Office and the United States Court of Federal Claims.