Sneak Preview: Recipients Advised To Know Award’s Effective Date
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) Grant recipients, as well as their subrecipients, are encouraged to fully understand the effective date of their federal awards to know which version of the Office of Management and Budget (OMB) uniform guidance applies to their award, an auditor told attendees at the recent National Grants Management Association’s annual training conference.
OMB issued the 2024 revisions to Title 2 of the Code of Federal Regulations (C.F.R.), including the uniform guidance (2 C.F.R. Part 200), in April 2024, noting that the revisions generally would become effective for new awards as of Oct. 1, 2024, although federal agencies could adopt provisions in the guidance earlier than that date. While some agencies implemented certain provisions within subparts A-E of the guidance earlier than the effective date, most maintained the Oct. 1 implementation for new awards. The provisions in the revised subpart F, including the $1 million single audit threshold, are effective for recipient fiscal years beginning on or after Oct. 1, 2024; therefore, these provisions would first apply to entities with a Oct. 1, 2024-Sept. 30, 2025, audit fiscal year.
Troy Rector, audit shareholder at Clark Nuber P.S., discussed language included in a Jan. 15 guidance issued by the Council on Federal Financial Assistance (COFFA) that provided more clarity on effective dates of awards. As stated in this guidance, new direct federal awards issued on or after Oct. 1, 2024, that do not specifically reference in the terms and conditions which version of the uniform guidance applies “may be assumed to apply the 2024 version.”
However, amendments issued on or after Oct. 1, 2024, to an existing award made before that date that applied a prior version of the uniform guidance may be assumed to continue applying the previous version of the guidance unless the amendment explicitly applies the 2024 revisions to the award. “If you had an award that was issued prior to Oct. 1, 2024, and you receive an amendment today, if that amendment doesn’t specifically state anything about adopting the 2024 revisions of the uniform guidance, the existing version still applies to that award,” Rector noted. Direct federal awards issued before Oct. 1, 2024, that applied the prior version and have not been amended would continue to apply the previous version of the guidance. (Editor’s note: Both versions of the uniform guidance are included on the Thompson Grants website.)
(The full version of this story has now been made available to all for a limited time here.)
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