HHS Adopting Uniform Guidance Closeout Provisions
This sort of came out the blue, although we’re all for it. The Sept. 15 Federal Register included a notice from the Department of Health and Human Services (HHS) stating that it would start following the closeout provisions within the uniform guidance (§200.344) rather than its existing closeout requirements at 45 C.F.R. §75.381.
HHS codified the original version of the uniform guidance in December 2014 at 45 C.F.R. Part 75. However, when the Office of Management and Budget (OMB) revised the uniform guidance at 2 C.F.R. Part 200 in August 2020, HHS did not amend its regulations to reflect all the changes, and maintained more restrictive closeout provisions compared to the revised uniform guidance. Concerned that the differing provisions “may lead to recipient confusion and inconsistencies in closeout timing,” as well as “report submission delays [that] can affect closeout task reconciliation and effective completion,” HHS stated in the notice that adhering to the uniform guidance provision at §200.344 would provide more time for recipient compliance and conform with other federal awarding agencies.
Therefore, as of Oct. 1, HHS will follow the uniform guidance provisions, which:
- increase the number of days for recipients to submit closeout reports and liquidate all financial obligations from 90 calendar days to 120 calendar days after the end of the period of performance;
- require awarding agencies to complete closeout actions no later than one year after the end of the period of performance unless otherwise directed by authorizing statutes; and
- require awarding agencies to close out awards within one year of the end of the period of performance based on available information and report the recipient to the OMB-designated integrity and performance system (currently SAM.gov Responsibility/Qualification).
We definitely favor any action that improves uniformity across the grants spectrum and reduces grantee burden.
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Virtual Advanced Federal Grants Forum | Oct. 25-26, 2023 | Virtual Event
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