Sneak Preview: OMB Announces 2024 Update To C.F.R. Title 2, Uniform Guidance
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) The Office of Management and Budget (OMB) recently announced the issuance of the 2024 final revisions to Title 2 of the Code of Federal Regulations, including the uniform guidance (2 C.F.R. Part 200). The revised guidance becomes effective for federal awards issued on or after Oct. 1, although awarding agencies may opt to adopt the revised guidance for financial assistance awarded prior to that date.
OMB unveiled a pre-publication version of the “Guidance for Federal Financial Assistance” on April 4, which has been submit for publication in the Federal Register. Along with the uniform guidance (2 C.F.R. Part 200), the recent action also includes revisions to other parts within Title 2, subtitle A, which are: Part 25, Universal Identifier and System for Award Management; Part 170, Reporting Subaward and Executive Compensation Information; Part 175, Award Term for Trafficking in Persons; Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement); Part 182, Governmentwide Requirements for Drug-Free Workplace (Financial Assistance); Part 183, Never Contract with the Enemy; and Part 184, Buy America Preferences for Infrastructure Projects.
Simultaneously, OMB, working with the Council on Federal Financial Assistance, included a discussion about the Title 2 revisions within a newly issued governmentwide implementation plan that aims to reduce burdens when administering federal financial assistance (OMB Memorandum M-24-11). M-24-11 also discusses both pre-award and post-award actions that federal agencies can take to promote transparency and equity. OMB further released a Unform Guidance Reference Guides document, which addresses provisions in the updated guidance that (1) promote the use of federal funds for evaluation and data activities; (2) support community engagement; (3) simplify the notice of funding opportunity (NOFO); (4) promote labor standards; and (5) reduce burden.
“These revisions will improve stewardship of federal funds, promote equitable access to programs and services, reduce administrative burden for agencies, applicants and recipients, and facilitate streamlined and effective oversight and implementation of federal programs,” OMB states in M-24-11. “Among other things, the revisions eliminate several prior approval requirements, increase multiple thresholds that trigger additional requirements, and clarify requirements for agencies and recipients.” The memo requires federal agencies to submit a plan by May 15 to OMB for implementing the revisions.
OMB issued proposed revisions to Title 2 in October 2023 and received more than 6,000 comments in response. In revising the uniform guidance, OMB generally maintains the current numeric structure of the existing guidance (although numerous changes were made within individual provisions that affect current citation references), but it does add one new provision at §200.217 on whistleblower protections.
(The full version of this story has now been made available to all for a limited time here.)
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