Sneak Preview: NOFO Shakeup, Subaward Threshold Increase Proposed for Appendices

(The following was excerpted from a recent Thompson Grants Compliance Expert article.) Federal agencies would be required to simplify and streamline notices of funding opportunities (NOFOs) under the Office of Management and Budget’s (OMB) recently proposed revisions to Appendix I to the uniform guidance (2 C.F.R. Part 200). Other changes to the appendices would include an increase to the subaward threshold under the indirect cost-related requirements for specific types of recipients.

In Appendix I, OMB proposes to revise the current language in its entirety to improve the quality and accessibility of funding opportunities. “Specifically, the proposed revisions to Appendix I intend to: (1) follow plain language principles; (2) group similar items together to streamline content; (3) align sections more closely to the application process; (4) include basic information at the top of a NOFO so that applicants can more easily make decisions about whether or not to apply; (5) clearly define what must be included in a section of the NOFO versus what is at an agency’s discretion; and (6) provide flexibility to agencies while also giving applicants a common way to find information in every funding opportunity,” according to OMB.

The proposed revisions to Appendix I would begin with a discussion on general requirements, then a list of required sections and information that federal agencies must include in a NOFO, as follows: (1) basic information; (2) eligibility; (3) program description; (4) application content and format; (5) submission requirements and deadlines; (6) application review information; (7) award notices; (8) post-award requirements and administration; and (9) other information (optional).

The general requirements section under the proposed revisions would call for agencies to include basic information within the NOFO such as the federal agency name, funding opportunity title, announcement type (i.e., initial announcement or modification to a previously announced opportunity), funding opportunity number, Assistance Listings number and funding details. Agency contact information would also be required.

This section also would require agencies to include an executive summary, which is a brief description written in plain language and summarizing the goals and objectives of the program, the target audience and eligible recipients. The text of the executive summary should not exceed 500 words.

It also would require agencies to include key dates under the NOFO, including due dates for submitting applications, as well as for any letters of intent or preapplications. For any announcement issued before a program’s application materials are available, key dates also include the date on which those materials will be released; and any other additional information, as deemed applicable by the federal agency. If possible, the federal agency should provide an anticipated award date. If the NOFO is evaluated on a “rolling” basis, the federal agency should provide an estimate of the time needed to process an application and notify the applicant of the federal agency’s decision.

The proposed revisions to Appendix I, under the discussion of eligibility, would remove the term “matching” in preference to “cost sharing”, as OMB notes that matching is a type of cost sharing (see “OMB Proposes Uniform Treatment for Revisions to Budgets, Program Plans”).

(The full version of this story has now been made available to all for a limited time here.)

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