Sneak Preview: COFFA Document Includes Details On Implementing 2024 UG Revisions
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) The Office of Management and Budget (OMB) is now encouraging federal cognizant agencies for indirect costs to be especially receptive to recipient requests to renegotiate their current indirect cost rate agreements (NICRAs) that are in effect beyond Oct. 1, 2025, according to a recent document issued by the Council on Federal Financial Assistance (COFFA) addressing the upcoming Oct. 1, revised uniform guidance implementation date.
The Aug. 15 document provides supplemental information to federal agencies about NICRAs and other aspects of grants administration to help both agencies, as well as recipients, better transition to requirements under the revised Title 2 of the Code of Federal Regulations, including the uniform guidance (2 C.F.R. Part 200). The document offers additional details on OMB’s April 22 final guidance issuing the 2024 revisions and OMB Memorandum M-24-11, “Reducing Burden in the Administration of Federal Financial Assistance.”
The document emphasizes that federal agencies must take appropriate steps to ensure that the 2024 revisions are effective for all federal awards entered on or after Oct. 1. Agencies also should ensure their award templates, terms and conditions, notice of funding opportunity (NOFO) templates, policies and procedures, and other program documents and policies related to federal financial assistance should be updated to reflect the 2024 revisions for awards issued following the effective date.
For existing awards, OMB is strongly encouraging federal agencies to apply the 2024 revisions to any amendments they make to awards on or after Oct. 1 that provide additional funds. It also is encouraging agencies to amend existing awards so that the awards comply with the 2024 revisions if they will extend into FY 2025 and beyond. If an agency amends an existing award, the 2024 revisions will generally apply to activities on or after the date of amendment.
“Agencies may never retroactively apply the 2024 revisions to past activities that preceded the effective date of the amendment if doing so would impose additional substantive requirements on recipients (such as requirements increasing burden),” the document explains. “However, if memorialized in the amendment or through formal written notice, an agency may provide written approval to recipients allowing them to apply specific provisions of the 2024 revisions that reduce burden on recipients to activities that preceded the amendment. This flexibility to provide written approval reducing burden for past activities does not apply to revisions of indirect cost rates or de minimis rates.”
(The full version of this story has now been made available to all for a limited time here.)
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