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2024 will be remembered as a pivotal year in the grants community. With noteworthy events such as the issuance of revisions to Title 2 of the Code of Federal Regulations, including the uniform guidance at 2 C.F.R. Part 200, and a presidential election that could shake up the entire landscape of how federal awards are issued and overseen, as well as which programs are funded, as we enter 2025, recipients of federal awards are adjusting to new processes and planning for future governmental changes that will affect their awards going forward.
While grant recipients and subrecipients update their policies and procedures to address the 2024 uniform guidance revisions, other entities such as auditors need to respond to these and other changes that occurred in 2024. Of note, the Government Accountability Office (GAO) revised the Government Auditing Standards (GAGAS), also known as the “Yellow Book,” in 2024, making extensive changes generally in chapter 5. In addition, auditors and auditees are now adjusting to submitting audits and searching for information at the General Services Administration’s (GSA) Federal Audit Clearinghouse (FAC.gov) website.
Some actions of note that were taken this year will not go into effect until 2025. This includes the Department of Health and Human Services’ (HHS) October 2024 adoption of the uniform guidance, under which the agency — as of Oct. 1, 2025 — would remove its current financial assistance guidance at 45 C.F.R. Part 75 that HHS recipients follow and move HHS exemptions within this guidance to Title 2, while other guidance now under Title 45 will be included in the HHS Grants Policy Statement. In addition, the subpart F provisions of the 2024 uniform guidance revisions will affect audits beginning with nonfederal entity fiscal years starting Oct. 1, 2024, so the first audits that would apply the amended subpart F provisions would be those with fiscal years ending Oct. 1, 2025.
Thompson Grants presents our list of 10 of the most important developments related to federal financial assistance in 2024, and some projections on issues to watch for in 2025.
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