Uniform Guidance Proposed Revisions

In September, the Office of Management and Budget (OMB) published proposed changes to Uniform Guidance for Federal Awards (2 CFR 200) for research grants and contracts. The full text is available here. Originally announced in 2013, Uniform Guidance went into effect on December 26, 2014, and was meant to streamline all the prior rules and regulations for grants and contracts, and across federal agencies. For more information, review “OMB Uniform Guidance” (2014) linked here.

These new proposed changes are meant to reduce administrative burdens and provide clarity to some sections by using plain language and more current terminology. 

Some of the notable proposed changes include: 

  1. An increase in the single audit threshold from $750,000 to $1,000,000
  2. Use of the term “recipient or subrecipient” instead of the current term, “nonfederal entity”.
  3. An increase in the de minimis facilities and administrative cost rate from 10% to 15%, for those institutions who do not have a negotiated rate agreement.
  4. An increase in the equipment threshold from $5,000 to $10,000
  5. An increase in the subaward exclusion threshold from $25,000 to $50,000 modified total direct costs base
  6. New language to remove many current prior written approval requirements

The OMB allowed interested individuals and organizations to submit comments for 60 days. As research administrators, it is important to understand that some changes are anticipated and watch for more information. If codified and implemented, changes to the Uniform Guidance will go into effect within 90 days and will have an impact on the way we manage grants and contracts, and work with federal agencies and each other.

Cross-Post Source: RACC January Newsletter – Lauren Zajac, MPA, CRA – University of Arizona