More Federal Agencies Adopt the Uniform Guidance
Don’t look now but we have some newcomers to the party! The list of federal agencies that have adopted the Office of Management and Budget’s uniform guidance (2 C.F.R Part 200) has grown since the guidance initially was released in 2013.
Twenty-eight federal agencies and offices, through a Dec. 19, 2014, joint interim final rule, incorporated the uniform guidance into their grant rules and regulations, effective Dec. 26, 2014. These regulations, which can be found in Title 2, subtitle B, also include agency exceptions to the uniform guidance.
These agencies are the Agency for International Development (2 C.F.R. Part 700); Corporation for National and Community Service (2 C.F.R. Part 2205); Department of Agriculture (2 C.F.R. Parts 400, 415, 416, 418 and 422); Department of Commerce (2 C.F.R. Part 1327); Department of Defense (2 C.F.R. Part 1104); Department of Education (2 C.F.R. Part 3474); Department of Energy (2 C.F.R. Part 910); Department of Health and Human Services (2 C.F.R. Part 300); Department of Homeland Security (2 C.F.R. Part 3002); Department of Housing and Urban Development (2 C.F.R. Part 2400); Department of the Interior (2 C.F.R. Part 1402); Department of Justice (2 C.F.R. Part 2800); Department of Labor (2 C.F.R. Part 2900); Department of State (2 C.F.R. Part 600); Department of Transportation (2 C.F.R. Part 1201); Department of the Treasury (2 C.F.R. Part 1000); Department of Veterans Affairs (2 C.F.R. Part 802); Environmental Protection Agency (2 C.F.R. Part 1500); Executive Office of the President, Office of National Drug Control Policy (2 C.F.R. Part 3603); Gulf Coast Ecosystem Restoration Council (2 C.F.R. Part 5900); Institute of Museum and Library Services (2 C.F.R. Part 3187); National Aeronautics and Space Administration (2 C.F.R. Part 1800); National Archives and Records Administration (2 C.F.R. Part 2600); National Endowment for the Arts (2 C.F.R. Part 3255); National Endowment for the Humanities (2 C.F.R. Part 3374); National Science Foundation (2 C.F.R. Part 2500); Small Business Administration (2 C.F.R. Part 2701) and Social Security Administration (2 C.F.R. Part 2300).
However, since the issuance of that joint final rule, three other agencies have adopted the uniform guidance. These are the Election Assistance Commission (2 C.F.R. Part 5801); Federal Communications Commission (2 C.F.R. Part 6000); and as of this month, the U.S. Agency for Global Media (2 C.F.R. Part 1900). In addition, another change of note is that Title 2 now has a new, well, “title.” This week, the name of Title 2 changed from “Grants and Agreements” to “Federal Financial Assistance,” which was expected per the April 22, 2024, revisions to Title 2, including the uniform guidance, that took effect for awards issued on or after Oct. 1, 2024.
Another thing to note from OMB is that it plans to soon issue a Title 2 Frequently Asked Questions (FAQ) document, similar to the one it released after issuing revisions to the uniform guidance in 2020. However, this version will only update questions in the current 2021 version of the FAQ to make them applicable to the 2024 revisions, and delete any questions that are outdated. It will not include any new questions.
As we prepare to enter the holiday season, it’s important to make sure everyone is caught up on the latest on regulations and policies affecting federal financial assistance. We at Thompson will continue to follow any developments related to Title 2 should there be further changes going forward.
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