Revised Uniform Guidance Set For Release This Week

We expected it would happen sometime this month, and now it’s official. The Office of Management and Budget (OMB) is set to publish its final revisions to the uniform guidance in the Federal Register on Thursday. A lengthy inspection document – over 300 pages long – is available here.

After scanning through OMB’s response to more than 1,200 comments submitted on the proposed revisions issued in January, it appears that OMB opted to maintain its proposed language in many cases but made numerous clarifications to better address its intent throughout the revised guidance.

However, one of the more interesting final revisions relates to a new requirement at §200.414(h) for nonfederal entities to post their negotiated indirect cost rate to a public website. There was a lot of concern about this proposed provision, particularly from tribal organizations, based on privacy and competitive reasons and concerns about comparing rates. OMB has now exempted tribal entities from the requirement and listed details about what exact information grantees must provide (i.e., federally negotiated indirect rate, distribution base and rate type).

OMB also has put off a requirement in the proposed rule at §200.513(a)(3)(ii) to evaluate this year’s audits for a governmentwide single audit quality initiative, as the COVID-19 pandemic is creating many difficulties in performing audits this year. The provision is maintained; it just doesn't state which year to begin the initiative. OMB also made some key adjustments in the final revisions under the procurement provision to increase clarity.

Although the provision numbers in Subpart C (pre-award) will now change, once the revised guidance is effective, because OMB added a new §200.202 and pushed subsequent Subpart C (pre-award) provisions forward, it has now retained §200.309 (which was proposed for deletion), therefore the numbering system in Subpart D (post-award) remains consistent to the current form, thereby assisting grantees who would’ve had to change their internal policies to reflect the new provision numbers in Subpart D.

The final guidance is slated to go into effect three months after it is posted in the Federal Register (i.e., agencies must implement them in their regulations around Nov. 13). Grantee organizations should get up to speed now so that they are prepared for these changes, and be aware if their awarding agency receives an exception to these provisions in their agency implementation of the revised guidance.

And as always, check with Thompson Grants to get informed on the guidance revisions through our training offerings and publication updates. How big are these changes? As they said in the movie “Spinal Tap”, “This one goes to 11!”

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