OMB Plans To Issue FAQ on the Revised Uniform Guidance ‘Soon’

Everyone in the grants community still confused about the August 2020 revisions to the uniform guidance at 2 C.F.R. Part 200 should be glad to know that the Office of Management and Budget (OMB) soon plans to issue a new set of Frequently Asked Questions (FAQs) pertaining to the revised guidance. Once issued, the document will be available at the Chief Financial Officers Council (CFOC) website.

For historical reference, when OMB initially released the uniform guidance in December 2013, it subsequently issued a FAQ document containing numerous questions it had received from stakeholders pertaining to the guidance. OMB added later updates to this document, most recently in July 2017, as it continued to gather applicant and recipient queries. When OMB revised the uniform guidance in August 2020, certain responses to questions within the now-outdated FAQ were rolled into the revised guidance.

During an information exchange webinar with the grants community on Thursday, OMB’s Gil Tran stated that it would soon publish an updated FAQ on the CFOC website with responses to 146 questions. Tran said the document would address questions related to all parts of the guidance, including the effective date and the use of the de minimis indirect cost rate.

Also during the webinar, OMB’s Rhea Hubbard discussed grant-related programs under the American Rescue Plan Act (ARPA) (Pub. L. 117-2) and OMB’s recent memorandum M-21-20, Promoting Public Trust in the Federal Government through Effective Implementation of the American Rescue Plan Act and Stewardship of the Taxpayer Resources, which encourages fair and equitable administration of financial assistance and valuable program outcomes, and enables federal agency to provide certain flexibilities for grant applicants and recipients. (Thompson Grants has detailed these flexibilities in previous articles.) In response to an attendee question as to whether these flexibilities only apply to ARPA funding, Hubbard emphasized that although M-21-20 generally discusses federal agency implementation of new programs under the ARPA, these flexibilities, if adopted by the awarding agency, will be available not only to recipients with COVID-19-related awards, but also those with assistance awards not related to COVID-19.

Join us for our following Thompson Grants event:
Virtual Federal Grants Forum: For State & Local Governments | May 11 - 12, 2021
Federal Grants Forum For Institutions of Higher Education | July 21 - 22, 2021