Updates to Uniform Guidance
The Office of Management and Budget (OMB) has updated the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Audit (Uniform Guidance) originally effective in 2014. The revisions are intended to reduce burden of grant recipients, provide guidance and clarification on requirements, and improve overall federal grant management. Most of the revisions are effective for new awards issued on or after November 12, 2020.
The changes primarily impact the entities expending federal grants. The following are the significant changes to Uniform Guidance.
- Definitions are combined into the new Section 200.1. The revision includes new definitions and updated definitions. Noteworthy changes include:
- The definition of Catalog for Federal Domestic Assistance (CFDA) number has been replaced with the new term Assistance Listings number.
- Other definitions updated include revisions to improper payment, questioned costs, and period of performance.
- Clarification of must versus may related to Uniform Guidance requirements. (Section 200.101)
- Procurement standards have been changed for the following:
- Procurement methods are grouped into three categories of informal (micro-purchase/small purchase), formal (sealed bids/proposals) and noncompetitive (sole source), Section 200.320. The new informal procurement method may be used when the federal award purchase is under the simplified acquisition threshold.
- To match other guidance, the micro-purchase threshold was increased to $10,000 and the simplified acquisition threshold was increased to $250,000.
- Recipients may increase their micro-purchase threshold if certain requirements are met (Section 200.320). The recipient may self-certify annually a threshold up to $50,000. The self-certification must include a justification, clear identification of the threshold, and other supporting documents. A formal approval process by the Federal government is required for thresholds above $50,000.
- Adding the domestic preferences for procurement requirements encouraging use of goods and products produced in the United States (Section 200.322).
- The time for direct awards closeout reports increased from 90 to 120 days (Section 200.344).
- The revised guidance clarifies that any recipient without a current negotiated indirect cost rate may use the 10 percent de minimis rate. Previously, the de minimis rate could only be used for recipients that have never received a negotiated indirect cost rate.
The two changes that are effective upon issuance of the Uniform Guidance revisions on August 13, 2020 are changes with Section 200.216 related to prohibitions for certain telecommunication and video surveillance services/equipment and Section 200.340 regarding a federal agency’s ability to terminate an award.
What should organizations expending federal grants do related to the Uniform Guidance revisions? Here are some suggestions for recipients:
- Determine the person within the organization who will review and evaluate the changes.
- Identify the timing for applying the changes by determining grants awarded after the effective date.
- Review the organization’s written federal grant policies and procedures for potential updates.
The Uniform Guidance revisions can be accessed at the following link, Guidance for Grants and Agreements. Please contact the experts at KT with questions regarding the Uniform Guidance revisions.