The Wait Begins as Title 2 Comment Period Ends
As Tom Petty sang a few decades ago, “The Waiting is the Hardest Part.” As of this Monday’s comment period deadline, the grants community had made its feelings known about the Office of Management and Budget’s (OMB) Oct. 5 proposed revisions to Title 2, including the uniform guidance (2 C.F.R. Part 200), by submitting nearly 1,000 comments. Now we must wait a few weeks to see how OMB will respond to these comments in its final version of the revisions. At the start of 2023, OMB had expressed that it sought to finalize the revisions by the end of the year. Is that still possible? We’ll have to wait and see.
To be exact, a glance at Regulations.gov shows that 956 comments had been submitted as of noon on Dec. 5, the day after the comment deadline. Regulations.gov is continuing to process the comments and only about half were ready for public viewing as of noon, Dec. 5. Over the next few days, we’ll get a chance to see more of these comments from individuals, auditors, associations and other stakeholders. Thompson Grants intends to review some of these comments and post an article on Dec. 11 on topics within the proposed revisions that received support and those that raised concerns.
The grants community also should be aware that the date when the revisions are released as final may not necessarily be the effective date. When OMB previously revised the uniform guidance in August 2020, only two provisions within those changes became effective immediately. The bulk of those revisions went into effect on Nov. 12, 2020. Therefore, we’ll have to see when the pending revisions become effective.
Speaking of waiting, another agency has opted to extend its comment period on another topic related to federal funding. The Department of Health and Human Services Office of Research Integrity recently issued a 30-day extension on its proposed rule to update the current regulations for addressing misconduct in federally funded research. Although the original comment period was today (Dec. 5), the new comment deadline is Jan. 4, 2024. Thompson Grant subscribers can find out more about this proposed rule here.
We encourage everyone applying for or receiving federal financial assistance, as well as their subrecipients, contractors and auditors, to follow closely the developments over the next few weeks to see when OMB issues its final version of the Title 2 revisions. OMB has a lot to consider as it evaluates the myriad comments. Once the final guidance is released, rely on Thompson Grants to provide you the most useful information on the revisions and how they will impact your federal funding and oversight.
