Sneak Preview: OMB Updates 2 C.F.R.: Frequently Asked Questions

(The following was excerpted from a recent Thompson Grants Compliance Expert article.) The Office of Management and Budget (OMB), prior to the presidential transition, issued an updated version of the 2 C.F.R. 200: Frequently Asked Questions (FAQ), which included several new questions and answers to address specific queries related to indirect cost rates.

The 22-page document — which reflects OMB guidance based on the 2024 revisions to the uniform guidance that became effective for awards issued on or after Oct. 1, 2024 — does not include every question that was included in OMB’s previous FAQ on Title 2 of the Code of Federal Regulations (C.F.R.) that it released in 2020 following that year’s revisions to the guidance.

“OMB only retained questions and answers in this document that seemed to be of the most significance or continuing relevance for the federal financial assistance community, including federal agencies and recipients,” the FAQ states. “OMB did not retain FAQs that were directly incorporated in the 2024 revision or on issues for which the policy is now clearly stated in the updated version of the guidance.”

As stated in previous versions of the FAQ, OMB emphasizes that if there is any discrepancy between the FAQ and OMB’s guidance at Title 2, which includes the uniform guidance (2 C.F.R. Part 200), the guidance published in Title 2 prevails.

Overall, the updated FAQ includes 100 questions and answers. Most of the questions were similar in wording to the 2020 FAQ, while some were altered to address changes in the 2024 guidance (e.g., new dollar thresholds) or were presented in a clearer manner. Answers to these questions reflect any updates that were made in the 2024 revisions.

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

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