If you are referring to CFDA # 10.447, then you are correct, but only as far as it relates to NFP organizations. If you are a for-profit, then I would not see me using the compliance supplement for anything other than as an idea generator for developing related audit steps. As far as specific policies and procedures, I am a little unclear about what is required. Based on the reading of UG, here is what I found.
200.110 – Effective/Applicability Date.
(a) The standards set forth in this Part which affect administration of Federal awards issued by Federal agencies become effective once implemented by Federal agencies or when any future amendment to this Part becomes final. Federal agencies must implement the policies and procedures applicable to Federal awards by promulgating a regulation to be effective by December 26, 2014 unless different provisions are required by statute or approved by OMB.
Of course, we have the requirement for procurement in 200.317. There are procedures listed in 200.305 under Payment.
If we look at just the word “procedures” we get the following references:
- Financial management .302
- Contract cost principles
- Real property .311
- Equipment .313
- Intangible property 3.15
- Procurement .317 & .318-.320
- .324 Federal awarding agency or pass-through entity review
- Pass-through entities .331
- Opportunities to object, hearings and appeals .341
- Allowability of costs .403
- Indirect (F&A) Costs .414
- Audit services .425
- Lobbying .450
- Program-specific audits .507
- Scope of audit .514
Okay, after reviewing this list, I will admit to being just a little confused about how all of these things apply specifically to the program. So, to the extent these items apply to my program, I cannot argue that these policies are relevant, but it is hard to develop a specific method of applying each of these until you get to the individual items you can identify.