On October 5, 2023, the Office of Management and Budget (OMB) proposed revisions to OMB Guidance for Grants and Agreements, which includes 2 Code of Federal Regulations Part 200 (Uniform Guidance). The proposed revision reflects comments received from Federal agencies and those received in response to the OMB Notice of Request for Information that was published in the Federal Register in February 2023.
OMB’s Objectives for the Revisions
The OMB’s objectives for the proposed revisions to the Uniform Guidance include:
- Incorporating statutory requirements and administrative priorities,
- Reducing agency and recipient burden,
- Clarifying sections that recipients or agencies have interpreted in different ways, and
- Rewriting applicable sections in plain language, improving flow, and addressing inconsistent use of terms.
Overview of Proposed Uniform Guidance
The proposed Uniform Guidance is nearly 500 pages long; the most significant revisions include the following:
- Increase the Single Audit threshold to $1 million from $750,000.
- Increase the de minimis indirect cost rate percentage to 15% from 10%.
- Increase the threshold used to define a capital expenditure to $10,000 from $5,000.
- 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 terms “recipient” or “subrecipient” in lieu of non-federal entity throughout Subpart A to Subpart E.
- Remove 10 items currently included in the listing of prior written approval requirements in section 200.407.
- 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).
| Practical Consideration: The list above includes only the most significant proposed changes. Auditors and auditees should refer to the draft of the proposed revisions to the Uniform Guidance posted to the Federal Register at www.federalregister.gov/documents/2023/10/05/2023-21078/guidance-for-grants-and-agreements. The redline version of the proposed changes can also be viewed, at www.cfo.gov/assets/files/Uniform%20Grants%20Guidance%20Revisions%20-%20Redline%20(2023).pdf. |
The OMB has requested that interested parties submit any comments about the proposed changes by December 4, 2023.
