Navigating the Latest Uniform Guidance Changes: Your Key to Proactive Grant Management

In a bold move aimed at slashing administrative red tape and boosting efficiency in federal grant management, the Office of Management and Budget (OMB) has unveiled pivotal updates to the Uniform Guidance. Effective from October 1, 2024—with potential early adoption by federal agencies—these changes promise to reshape how organizations handle grant awards going forward. 

Key Updates

De Minimis Indirect Cost Rate Increase (2 CFR 200.414): 

• Elevates de minimis rate to 15% over modified total direct cost (MTDC). 

• Offers flexibility for recipients to opt for a lower rate and includes the first $50,000 of any subaward in the MTDC base. 

Single Audit Threshold Increase (2 CFR 200.501): 

• Raises threshold to $1 million for federal fund expenditures, necessitating Single Audit or Program-Specific Audit. 

Equipment-Related Thresholds (2 CFR 200.313): 

• Increases equipment acquisition threshold to $10,000, with tribal entities gaining leeway in disposal procedures. 

Fixed Amount Awards and Subawards (2 CFR 200.201): 

• Requires identification of incomplete activities at fixed amount award conclusion. 

• Expands subaward limit to $500,000 with federal agency approval. 

Procurement by States and Indian Tribes (2 CFR 200.317): 

• Grants tribal governments autonomy in procurement standards.

Proactive Approaches for Your Organization 

As these pivotal changes approach, proactive engagement is essential to harnessing their benefits effectively. Here’s how your organization can prepare: 

• Review Internal Policies and Procedures: Update policies and procedures to align with new thresholds and requirements, ensuring clarity in documentation. 

• Educate Staff and Stakeholders: Conduct training sessions to familiarize key personnel with revised policies, their implications, and updated Uniform Guidance. 

• Assess Financial Systems and Controls: Verify that your financial systems can manage revised thresholds and compliance demands effectively. 

• Plan for Transition: Prepare for adjustments in reporting cycles, budgets, and staffing needs ahead of the implementation timeline. 

• Communicate Effectively: Maintain dialogue with grantors and partners to ensure alignment and clarity on revised expectations. 

• Engage with Auditors and Consultants: Seek guidance on adapting audit strategies to meet new Uniform Guidance requirements. 

• Stay Informed: Remain vigilant for additional guidance updates that may impact compliance and operational efficiency. 

By taking proactive steps to understand and implement these changes, your organization not only ensures compliance but also enhances operational efficiency. Embrace the opportunity to streamline processes and refocus efforts on achieving programmatic goals with federal funding. 

Need help? Let’s chat and see how Witt O’Brien’s can help your team prepare.  

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