Uniform Guidance Updates – 2024

Biden -Harris Administration Finalize Uniform Guidance Updates for 2024

Published: April 17, 2024

By: Elizabeth Tyson-Jankowski

Many of us, long timers, in the Non-Profit and Federally funded space remember the sweeping changes that occurred December 26, 2013, with the inception of 2 CFR 200 Uniform Guidance (“UG”) eCFR :: 2 CFR Part 200 — Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Since the original implementation of the “UG” we have seen updates in 2016 and 2019. These changes made significant impacts on how federally funded organizations operated.

As of April 04, 2024 the Biden – Harris Administration have finalized the proposed changes made at Draft Federal Register Notice and Revisions to the Uniform Guidance – Pre-publication Version – 9.21.23 (whitehouse.gov).

The official release, The Biden-Harris Administration Finalizes Guidance to Make Grants More Accessible and Transparent for Families, Communities, and Small Businesses | OMB | The White House, aims to reduce the burden on grant recipients and increase transparency.

Among these reductions are the following:

  • Update the definition of “equipment”, or capitalized expenditures, to include a threshold increase for this category from $5,000.00 to $10,000.00.
  • An increase from $5,000.00 to $10,000.00 to the allowable value of “unused supplies” at the end of the grant period of performance.
  • Change the excluded cost amount for sub-award costs under “Modified Total Direct Costs”, to increase from a $25,000.00 to $50,0000.00.
  • Increases the de minimis rate from 10 percent to 15 percent. This change will allow for a more reasonable and realistic recovery of indirect costs.
  • Includes guidance for recipients and subrecipients to charge administrative costs specifically associated with the closeout of a Federal award.
  • raise the Single Audit threshold from $750,000 to $1,000,000 .

In addition to the above, OMB has opened the forum for discussion regarding:

  • Establishing specific audit requirements for for-profit entities
  • Removing additional prior approval requirements
  • Challenges related to negotiating indirect costs, working with cognizant agencies, or any other topics related to indirect costs.
  • Expanding the guidance in Subpart F to include more specific requirements on the scope of an audit (“proper perspective”)

These topics may bring about changes in future updates beyond 2024.

A&O CPA’s are a non-profit and government exclusive firm dedicated to furthering the many missions of our clients.

About the Author:

Elizabeth is the Government & Non-Profit Services Manager for Andrea & Orendorff, CPAs in Kenosha, WI (a firm dedicated solely to servicing Government and Non-Profit entities). She has 15 years of experience in Government and Non-Profit Grant/Fund Accounting, Compliance, and Audit. Specializing largely in total grant management, policy development, contract and procurement negotiation and development, single audit oversight, and Indirect Cost rate negotiations and proposal development. Also providing training on regulatory requirements surrounding the FAR, DFAR, 2 CFR 200, and 29 CFR part 38.

Leave a Comment

Your email address will not be published. Required fields are marked *