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The Office of Management and Budget (OMB) in late September made available proposed revisions to Title 2 of the Code of Federal Regulations, including the uniform guidance at 2 C.F.R. Part 200. OMB’s aim is to finalize these revisions by the end of the year to make them effective for financial assistance awards in 2024. The revisions seek to incorporate statutory requirements and administration priorities, and reduce agency and recipient burden. OMB also has attempted to clarify its guidance by addressing sections that recipients or agencies have interpreted in different ways, and to rewrite applicable sections in plain English, improve flow and address inconsistent use of terms. The proposed revisions, however, did include noteworthy changes to the current guidance. For example, it would raise the single audit threshold from $750,000 to $1 million; amend the de minimis indirect cost rate level from 10% to 15%; increase the equipment and supply thresholds from $5,000 to $10,000; and revamp the Appendix I, Full Text of Notice of Funding Opportunity, to clarify the grant application process and to require the inclusion of an executive summary. How will these proposed changes affect awarding agencies and recipients/subrecipients of federal funds? Are these proposed revisions addressing the challenges faced by smaller recipients as intended? Could a higher single audit threshold lead to fewer audits and greater financial mismanagement? During this hour-long webinar, Thompson Grants Editor Jerry Ashworth asked questions to our board member panel to get their views on the latest proposed Uniform Grant Guidance changes.
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Panelists
Cornelia Chebinou, NASACT
Cornelia Chebinou has been the director of the Washington office of the National Association of Auditors, Comptrollers and Treasurers (NASACT) since August 1999. She serves as the primary liaison with Congress, the administration, federal agencies and other associations on national issues of intergovernmental finance while representing state governmental positions; providing information to the membership; and assisting in the development of policy. She has served as the point person for state finance officials on implementation of the American Recovery and Reinvestment Act, the recent COVID aid legislation and is a past co-chair of the National Grants Partnership and International Consortium of Public Finance Managers.
Eric Russell, CIA, CGAP, CGMS, MPA
Eric Russell is a professional auditor and management consultant with more than 15 years of experience, including serving as a municipal finance executive, government auditor and consultant, local government budget and legislative research professional, and nonprofit board member. He currently serves a director with ENJ PLLC where he is responsible for government regulatory compliance, process improvement, and public sector management consulting engagements. Eric previously served as deputy finance director with the city of Columbus, Ohio, responsible for grants management, facilities management, construction management, real estate management, and fleet management. He also spent 13 years with Crowe LLP where he served as a senior manager responsible for governmental audits, internal audits and consulting engagements. Eric currently serves as president of the Board of Directors of the National Grants Management Association and as a member of the Thompson Grants Advisory Board. He is a Certified Grants Management Specialist, Certified Internal Auditor, and Certified Government Auditing Professional. Eric holds a Bachelor of Business Administration from Stetson University and a Master of Public Administration degree from The Ohio State University.
Tiffany Kesslar, Esq., The Bruman Group, PLLC
Tiffany Kesslar, as a Partner at The Bruman Group, PLLC, advises clients on federal grants compliance, and conducts trainings and mock monitoring visits of non-federal entities for fiscal and programmatic grants compliance. She also works with clients and provides audit defense on the requirements of the Office of Management and Budget uniform guidance and other administrative regulations.
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