Make Note of Errors When Commenting on Uniform Guidance Revisions

The last week has been a whirlwind around here as we have been delving into the Office of Management and Budget’s proposed changes to the uniform guidance and other Title 2 regulations. The further we got into the revisions, the more it became obvious that it would require a greater reporting effort than we had originally planned. As it turns out, we wrote five separate lengthy stories on the changes, particularly to each subpart, and we still haven’t covered every revision. That’s why we are encouraging the grants community to take the time to thoroughly read the proposed amendments and make sure they submit comments on the revisions by the March 23 due date.

Stakeholders obviously should make their voice heard if they oppose some of the proposed changes, and conversely, they should respond to issues that they consider positive and that could reduce their burdens. But the comments shouldn’t stop there; they also should address errors within the proposal.

Consider back to the release of the 2019 Compliance Supplement. The document brought about some big changes compared to previous years’ supplements, but auditors soon realized that the version released in July 2019 had numerous errors that could have created auditor confusion when conducting engagements, as well as other quality control issues. For example, the Part 2 matrix had conflicting requirements when compared to corresponding tables in Part 4. In light of this, OMB took the unique step of releasing a revised 2019 Compliance Supplement correcting all these errors.

We hope to prevent this situation from happening again when it comes to these uniform guidance revisions. Let OMB know if you notice any factual errors as you read through the changes to determine if something needs to be addressed before the changes, if approved, eventually go final.

In some cases, the errors can be minimal and can be simple grammatical errors. For example, we noticed in the proposed revised definition for “capital assets,” OMB has a reference to “FSAB” (i.e., the Federal Accounting Standards Board) that should read “FASB.” Also, the proposed revisions to Subpart A would include a new term for “discretionary award,” which, as written, would be an “award in which the awarding agency, in keeping with specific statutory authority which enable the agency to exercise judgement (“discretion”) in selection the grant award recipient through a competitive process or based on merit of existing grant recipients.” We editors here realized that this is sentence fragment and an incomplete thought, and OMB should reword this so that it is clear.

The last thing we need is a finalized grants document out there that has wrong information. We already learned that lesson with the 2019 Compliance Supplement.

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