OMB To Announce Uniform Guidance Revisions April 4

Hold on to your hats, folks! The Office of Management and Budget (OMB) will be announcing this year’s revisions to Title 2 of the Code of Federal Regulations, including the uniform guidance at 2 C.F.R. Part 200, this Thursday, April 4. The announcement should include an unveiling of the effective date for the revised guidance, letting federal agencies, grant recipients and subrecipients and other stakeholders know when the revisions apply.

OMB will hold a one-hour webinar to officially present the release of the revised guidance from 2-3 p.m. Eastern time. Interested parties are encouraged to sign up early for the webinar.

For those who haven’t been keeping up with the latest on the upcoming revisions, OMB had four goals for updating the uniform guidance: (1) writing it in plain English to improve the grammar and flow and reduce the inconsistent use of terms; (2) reducing stakeholder administrative burden; (3) including statutory changes issued since the 2020 Title 2 revisions and implementing administration priorities; and (4) making clarifications to avoid multiple interpretations of the guidance.

OMB issued proposed revisions to Title 2 on Oct. 5, 2023, with a stakeholder comment period deadline of Dec. 4. It received thousands of comments submitted to the proposal. Among the key proposed revisions were:

• raising the single audit threshold from $750,000 to $1 million;
• raising the de minimis indirect cost rate from 10% to up to 15%;
• changing the wording from “nonfederal entity” to “recipient or subrecipient” in Subparts A-E;
• changing the equipment/supply threshold limit from $5,000 to $10,000;
• no longer requiring prior federal agency approval for 10 types of costs;
• adding a new §200.217, Whistleblower Protections;
• enabling federal agencies to issue information about awards in other languages;
• requiring clearer notices of funding opportunity, along with the addition of an executive summary of no more than 500 words: and
• allowing tribes to use their own procurement policies (now only allowed for states).

We will be watching closely to determine how OMB responded to the comments to the proposal, and if the proposed changes were amended in any way. Stay tuned for information from Thompson Grants as we work to let you know about the final revisions, when they become effective, and what the changes will mean for you.

Join us for our following Thompson Grants events:
Thompson Grants Workshop: Procurement | May 23, 2024 | Virtual Event
Federal Grants Forum | June 26-27, 2024 | Columbus, Ohio