Overview of Final Uniform Guidance Revisions for Federal Award Recipients

The Office of Management and Budget (“OMB”) previously published proposed changes to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly referred to as the “Uniform Guidance”) on October 5, 2023. Following the publication, there was a 60-day comment period ending December 4, 2023. The OMB published final guidance on April 22, 2024, which reflects the 829 public comments it received from public and federal agencies.

The revised Guidance for Federal Financial Assistance has four primary objectives: (1) incorporate statutory requirements and administrative priorities, (2) reduce agency and recipient burden, (3) clarification to reduce different interpretations between federal agencies and recipients, (4) and to rewrite applicable regulations to follow plain language principles. Some of the most significant revisions include:

• Increase the Single Audit threshold from $750,000 to $1,000,000
• Increase the fixed amount subawards that recipients may provide with written approval from the relevant Federal agency from $250,000 to $500,000.
• Increase the de minimis indirect cost rate percentage from 10% to 15%.
• Increase the threshold amount of subawards that recipients can apply to their indirect rate from $25,000 to $50,000 under modified total direct costs.
• Increase the threshold used to define a capital expenditure from $5,000 to $10,000.
• Increases the value of equipment that at the end of the grant award period may be “retained, sold, or otherwise disposed of with no further responsibility to the Federal agency” from $5,000 to $10,000.
• Increases the threshold for value of unused supplies that recipients are required to sell at the end of the grant award period from $5,000 to $10,000.
• Simplify language and program requirements including:
  • Use of plain language in grant announcements.
  • Removes requirement of English language in grant announcements and other relevant documents
  • Use the term “recipient” or “subrecipient” in lieu of “non-federal entity” throughout Subpart A to Subpart E.
• Revision emphasizes that recipients of Federal Funds may spend a portion of the funding on evaluation, which allows both Federal agencies and recipients to better understand to what extent intended goals of the funding are being achieved.
  • Revision in Section 200.455 states “costs related to data and evaluation are allowable” as well as providing examples of such allowable data and evaluation costs.
• Revised template for Notice of Funding Opportunity (NOFO) to reduce unnecessary obstacles when applying for Federal financial assistance.

The final guidance has an effective date of October 1, 2024.

Sources:

• Federal Register.gov | Guidance for Federal Financial Assistance
• CFO.gov | Uniform Grants Guidance 2024 Revision: Evaluation
• ECFR.gov | Code of Federal Regulations | Grants and Agreements
• Whitehouse.gov | Biden-Harris Administration Finalizes Guidance to Make Grants More Accessible and Transparent for Families, Communities, and Small Businesses