The Effective Date for the Uniform Guidance Revisions is Near

In pro football, near the end of each half, they have a stoppage in play known as the “two-minute warning.” At this point, you know at either halftime or the end of the game is near. Well, now that we’re too weeks away from its Oct. 1 effective date, we’ve reach something akin to the two-minute warning with regards to the 2024 revisions to Title 2 of the Code of Federal Regulations, including the uniform guidance at 2 C.F.R. Part 200.

The Office of Management and Budget (OMB) in April announced that it was revising Title 2 and the uniform guidance on Oct. 1, giving federal agencies and financial assistance award recipients a little more than five months to prepare for the changes. Some agencies, such as the National Aeronautics and Space Administration and the Gulf Coast Ecosystem Restoration Council, in recent days officially amended their regulations in Subtitle B of Title 2 to adopt the 2024 revisions. Numerous trainings have occurred since April to get everyone up to speed on the coming changes.

So now the clock ticks down on the requirements and dollar thresholds under the current guidance. What can we expect on Oct. 1? Well, we here at Thompson Grants previously posted an article that provides a good synopsis of OMB and the Council on Federal Financial Assistance’s implementation plan, which can be found here. Among some of the key points from that article:

• Federal agencies must take appropriate steps to ensure that the 2024 revisions are effective for all federal awards entered on or after Oct. 1, and 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.
• Negotiated indirect cost rate agreements (NICRAs) negotiated prior to Oct. 1 must continue to be honored by federal agencies and recipients. Cognizant agencies for indirect costs may, but are not required to, renegotiate NICRAs to reflect the new modified total direct cost (MTDC) base, but OMB encourages these agencies to accommodate requests to renegotiate existing NICRAs that are in effect beyond Oct. 1, 2025. Recipients with provisional rates in effect prior to Oct. 1 must finalize those rates using the provisional rate’s approved MTDC base.
• Future provisional rates must be negotiated with the new MTDC base on or after Oct. 1. Recipients with predetermined or fixed rates must use the new MTDC base beginning with the first proposal that is required on or after Oct. 1. Recipients preparing indirect cost rate proposals must apply the new MTDC base for proposals that are submitted to the cognizant agency for indirect costs on or after Oct. 1.
• Although the single audit provisions in subpart F become effective Oct. 1, the new $1 million single audit threshold and major program determination thresholds will apply to the nonfederal entity’s fiscal years beginning on or after Oct. 1, 2024. Therefore, for example, the current provisions and thresholds in subpart F will still apply to audits for auditees with fiscal years running of July 1, 2024, through June 30, 2025.

For all recipients of federal awards, now is the time to make sure your policies and procedures and financial systems are prepared to adapt to the changes in the uniform guidance for awards received after Oct. 1. The clock is ticking!

Join us for our following Thompson Grants event:
Nonprofit Legal, Finance, & Grants Conference | Oct. 1-2, 2024 | Arlington, Va.
Federal Grants Forum: Navigating the 2024 Uniform Guidance Changes | Oct. 29-30, 2024 | Virtual Event