21 Jul A Look at 2024 OMB Uniform Guidance Updates By: Kellie Brungard, GPC

Over the past year, you may have overheard grant professionals discussing potential OMB Uniform Guidance updates. If you are wondering what that means and what may apply to you or your organization, here is a quick look at what changes occurred and what you should know.

What is Uniform Guidance?

Office of Management and Budget (OMB), an agency within the Executive Office of the President, issues government-wide grants-related guidance for federal departments and agencies and is responsible for the maintenance of this document. Before 2013, federal grant requirements were located in multiple OMB circulars. OMB developed a comprehensive guide for the Federal government’s Administrative Requirements, Cost Principles, and Audit Requirements for federal awards that became effective in 2014. In essence, this updated, reorganized, and consolidated federal grant management requirements into a single document. You may have heard various terms such as Uniform Grant Guidance (UGG), supercircular, omnicircular, or 2 CFR 200. Technically, these refer to various components of the same document, called the Code of Federal Regulations (CFR) that is divided into 50 titles or broad areas of federal regulation. Title 2 of the CFR houses guidance and regulations for federal grants and agreements. Part 200 of Title 2 is the location for the UGG. There are six subparts and twelve appendices:

• Subpart A – Acronyms and Definitions (2 CFR 200.0 through 2 CFR 200.99)
• Subpart B – General Provisions (2 CFR 200.100 through 2 CFR 200.113)
• Subpart C – Pre-Federal Award Requirements and Contents of Federal Awards (2 CFR 200.200 through 2 CFR 200.213)
• Subpart D – Post Federal Award Requirements (2 CFR 200.300 through 2 CFR 200.345)
• Subpart E – Cost Principles (2 CFR 200.400 to 2 CFR 200.475)
• Subpart F – Audit Requirements (2 CFR 200.500 to 2 CFR 200.521)
• Appendices (Appendix I to Appendix XII)

How often do updates occur?

The original document became effective in December 2014. Since then, revisions have been made only a couple of times. In 2020, two new requirements were added in August, and the remaining revisions were made in November. In April 2021, updates were made to cross-references and terminology to align with the 2020/2021 revisions. The most recent updates are for 2024.

What updates were made?

The OMB’s recently approved revisions will go into effect on October 1, 2024. This overview highlights some of the most prominent revisions:

• Notice of Funding Opportunities (NOFO) posted by federal agencies should be communicated in plain language, efforts should be made to limit the length and complexity.
• Burden reduction revisions increase the value of equipment from $5,000 to $10,000 that at the end of the grant period “may be retained, sold, or otherwise disposed of with no further responsibility to the Federal agency.”
• Raising the level of single audit requirements from $750,000 to $1,000,000.
• Raising the De Minimis Indirect Rate that recipients may use for indirect costs without negotiating an alternative rate from 10% to 15%, and raising the amount of indirect costs a recipient can include in its base calculation of modified total direct costs for each subawardee from $25,000 to $50,000.
• Agencies will be able to translate grant notices or other documents into another language to increase accessibility to federal funding opportunities.
• Costs for certain administrative costs associated with closeout to be charged to the final budget period, and clarification of right to receive any remaining and available funds.
• Clarification of allowable costs associated with data and evaluation.

These revisions address key barriers prospective organizations encounter, such as language or indirect cost rates. They also change the single audit requirements to address the effects of inflation. If you want to learn more, you can read the OMB’s memo on the revisions, review the reference guide that outlines the changes in more detail, or review the redline document showing the specific revisions (with a strong cup of coffee).

If you are interested in learning more about grants management and how the 2 CFR 200 Uniform Guidance is applied to everyday practices, AGS offers an on-demand Grant Management Training Series produced by our certified grant management specialists (CGMS) staff members. Topics include handouts and resources for pre-award federal activities, grant management systems, allowability and cost principles, policies and procedures, and award closeout. Check out our website to learn more and sign up for our training newsletter.

If you think your organization’s policies and procedures may need to be reviewed and/or revised for compliance in light of the OMB update, our team of grant management specialists can help! Fill out the online form located here and select “I need help with grant management” from the list of available options.

This blog post is aligned with the Grant Professional Certification Institute’s Competencies and Skills.

Competency #5: Knowledge of post-award grant management practices sufficient to inform effective grant design and development

Skill 5.1: Identify standard elements of compliance