Revisions Effective Date Offers Prime Chance To Reflect on Policies

It came and went without much fanfare, but Friday, Nov. 12, 2021, was something of an important date for all financial assistance applicants and recipients. It marked the one-year anniversary of the effective date of the revisions to the Office of Management and Budget’s uniform guidance. Other than a couple of new provisions that immediately went into effect on Aug. 13, 2020, the uniform guidance revisions generally became effective on Nov. 12, 2020, for awards issued after that date and modifications to existing awards.

So what makes the anniversary of the effective date so special? Now would be a good time for grant recipients to fully evaluate their programs. Have their policies and procedures been updated to reflect the revisions to the uniform guidance? Are staff adequately following these policies and procedures? Where they hampered by any disruptions stemming from the COVID-19 pandemic that could have affected efforts to maintain compliance with the provisions in the revised guidance?

Award recipients should ensure that staff is aware of the key revisions pertaining to procurement (§200.320), closeout reporting dates (§200.344), and making contracts with certain foreign vendors (§§200.215, 200.216). In addition, because many of the provision citations were changed in the revised guidance compared to the original version, organizations should ensure that their internal policies and procedures are referencing the appropriate citation.

It is generally recommended practice for grant recipients to update their policies and procedures at least annually. Many people have used the two dates within the year when we switch to and back from Daylight Savings Time to check their smoke alarm batteries. Perhaps grant recipients could mark Nov. 12 on their calendar each year as a good time to take stock of their internal policies to verify they are up-to-date and that staff are following them. And as always, Thompson Grants line of compliance resources and training can help recipients along the way to help them avoid findings that can threaten their federal funding.

Join us for our following Thompson Grants events:
Thompson Grants Workshop: Preparing for the Annual Audit | December 9, 2021 | Virtual Event
Federal Grants Forum: Orlando | December 14 - 16, 2021