Four Crucial Steps Federal Grant Recipients Should Take Now to Comply with Revised Uniform Guidance 

The recent revisions to the Uniform Guidance are the largest in years both in terms of the amount and their impact on day-to-day grants management. As stated in a previous thought piece, these updates by the Office of Management and Budget (OMB) are intended to streamline, simplify, and enhance the accessibility of federal financial assistance.   

In this thought piece, we provide guidance for organizations—both newbies and those experienced in federal financial assistance—to be prepared to implement these revisions as the October 1st, 2024 deadline for federal agencies to adopt the latest Uniform Grants Guidance (UGG) approaches.

Here are four key actions your organization should consider: 

1. Update Policies and Procedures

• Review and Revise: Conduct a thorough review of your current policies and procedures to ensure they align with the revised Uniform Guidance. Update any outdated policies to reflect the new requirements such as:
  • Thresholds for equipment and supplies raised from $5k to $10k.  
  • The standard de minimis indirect cost rate increased from 10% to 15% over modified total direct costs (election of a lower rate is still permitted).  
  • The modified total direct cost can now include the first $50k in subaward costs as opposed to the original allotment of $25k.  
  • The annual expense threshold for single or program-specific audits increased from $750k to $1M.  
  • The maximum fixed amount for subawards increased from $250k to $500k.  
  • Recipients and subrecipients must incorporate cybersecurity measures into their internal controls to safeguard information (the OMB may provide additional guidance on specific guidelines, standards, and practices in the future).
    
    
• Documentation: Ensure all changes are well-documented and accessible to relevant staff members.
  
  
• Training: Provide training sessions for staff to familiarize them with the updated policies and ensure they understand how to implement them.

2. Enhance Financial Management Systems and Internal Controls 

• System Evaluation: Assess your current management systems to ensure they meet the revised requirements for tracking and reporting on grant funds.
  
  
• Automation: Consider investing in or upgrading software that can automate compliance with the new guidelines thereby reducing errors and improving efficiency.
  
  
• Internal Controls: Strengthen internal controls to safeguard grant funds and ensure proper use according to the revised Uniform Guidance. 

3. Strengthen Documentation and Reporting

• Documentation Practices: Improve documentation practices to ensure all grant-related activities and expenditures are well-documented and can be easily retrieved during audits or reviews.
  
  
• Reporting Accuracy: Review and enhance your reporting processes to ensure timely and accurate submission of financial and performance reports as required by the revised Uniform Guidance.
  
  
• Compliance Monitoring: Implement regular internal audits or compliance checks to identify and address any potential issues before they escalate. 

4. Engage in Continuous Training and Education 

• Ongoing Training: Provide continuous training and education opportunities for all staff involved in grant management to keep them updated on the revised Uniform Guidance and any future changes. This training should also be made available for current and future subrecipients.
  
  
• Workshops and Webinars: Participate in workshops, webinars, and other educational events offered by federal agencies or professional organizations to stay informed regarding best practices and new developments.
  
  
• Networking: Engage with other grant recipients and professional networks to share insights, challenges, and solutions related to the revised Uniform Guidance. 

By taking these actions, current and future federal grant recipients can ensure they are well-prepared to comply with the revised Uniform Guidance, thereby maintaining effective grant management practices and minimizing the risk of non-compliance. 

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