Published October 11, 2024, via Research News
Effective October 1, 2024
The Office of Management and Budget (OMB) provides guidance to federal sponsoring agencies on administrative requirements, cost principles, and audit requirements for federal awards. This guidance is referred to as the Uniform Guidance (UG) and may be found in the federal register under 2 CFR Part 200.
The OMB Guidance for Federal Financial Assistance – Final Rule introduces several revisions, including increases to thresholds for equipment/supplies, modified total direct costs (MTDC), de minimis rate, fixed amount awards, and single audit.
Federal Agencies implement the UG when developing their own guidelines for grants and cooperative agreements. Not all federal agencies have announced their implementation plans for the UG revisions that took effect on October 1, 2024.
The Council on Governmental Relations (COGR) has a detailed summary of the latest UG revisions.
Summary of impactful changes at WashU
Effective now:
- The de minimis rate changed from 10% to 15% for subrecipients that have never had a federally negotiated rate. New proposal applications should reflect this updated rate.
- Existing agreements are not required to adopt the new rate.
Future changes that will be part of our regular Facilities & Administrative (F&A) rate negotiation process
The earliest WashU will be able to implement these changes is July 2025. Further guidance will be shared as it becomes available.
- Equipment thresholds changed from $5,000 to $10,000*
- Thresholds for overhead on the first $25,000 of a subaward increased to $50,000*
*Do not utilize these new thresholds in your proposals until WashU has incorporated these changes in a formally negotiated rate agreement
Indeterminate change:
- Allowability of vacation payout upon termination.
- As it is currently written, the new UG no longer allows vacation payout upon termination to be directly charged to federal grants.
- We are hopeful there will be a technical correction to remove this requirement, but this remains uncertain.
- In the interim, technical solutions are being evaluated to assist with this change if the charge is indeed unallowable.
The Uniform Guidance page will continue to be updated as more information is made available, including when the federal agencies announce their guidance and conditions.