Overview of Proposed Uniform Guidance Revisions for Federal Award Recipients

Proposed Uniform Guidance changes expected to be finalized in 2024

In December 2013, the Office of Management and Budget (“OMB”) issued the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly referred to as the “Uniform Guidance”), which included vast changes to the administration and auditing of federal grants. Now that we have had about 10 years to adjust to the new regulations, the OMB has proposed new changes in an effort to provide clarity and reduce both agency and recipient burden.

Highlights of the proposed revisions

The proposed revisions to the Uniform Guidance are nearly 500 pages long. Some of the most significant revisions include the following:

• Increase the Single Audit threshold to $1 million from $750,000, potentially reducing the number of single audits required each year.
• Increase the de minimis indirect cost rate percentage to 15% from 10%, potentially increasing the number of recipients using the de minimum indirect cost rate.
• Increase the threshold used to define a capital expenditure to $10,000 from $5,000, reducing the administrative requirements related to lesser-valued items.
• Increase the exclusion threshold of subawards to $50,000 from $25,000 under modified total direct costs.
• Require the Schedule of Expenditures of Federal Awards to identify the recipient of a federal award in audits that cover multiple recipients.
• Use the term “recipient” or “subrecipient” in lieu of “non-federal entity” throughout Subpart A to Subpart E.
• Removal of items currently included in the listing of prior written approval requirements. Items removed include real property, equipment, direct costs, entertainment costs, exchange rates, memberships, participant support costs, selling and marketing costs, and taxes.
• Remove the existing requirement in paragraph (h) of section 200.414 for all indirect cost rates to be made publicly available on a government-wide website (however, this may be revisited once applicable systems are updated to allow for the posting of indirect cost rates).

The proposed changes were published in the Federal Register on October 5, 2023, which started a 60-day comment period ending December 4, 2023. The comments received are expected to inform the final changes, which are expected to be published in 2024.

The Keiter Not-for-Profit team will continue to monitor the Federal Register for publication of the final regulations and share when they are available.