In April 2024, the Office of Management and Budget (OMB) issued revisions to the OMB Guidance for Grants and Agreements, which is now called the OMB Guidance for Federal Financial Assistance. The revisions impact several parts of the guidance:
| Part 1 | About Title 2 of the Code of Federal Regulations and Subtitle A |
| Part 25 | Universal Entity Identifier and System for Award Management |
| Part 170 | Reporting Subaward and Executive Compensation Information |
| Part 175 | Award Term for Trafficking in Persons |
| Part 180 | OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Non-procurement) |
| Part 182 | Governmentwide Requirements for Drug-Free Workplace (Financial Assistance) |
| Part 183 | Never Contract with the Enemy |
| Part 184 | Buy America Preferences for Infrastructure Projects |
| Part 200 | Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards |
OMB’s revisions are intended to improve federal financial assistance management, transparency, and oversight through more accessible and easily understandable guidance. The guidance is being revised for four purposes and the final guidance describes how the changes satisfy those purposes as follows:
| Purpose | Changes to Accomplish |
|---|---|
| Incorporate statutory requirements and administration priorities | Ensure consistency with statutory authorities and provide further structural consistency throughout OMB 2 CFR |
| Reduce agency and recipient burden | Increase several thresholds that have not been updated for many years Revise template text for Notice of Funding Opportunity (NOFO) |
| Clarify sections that recipients or agencies have interpreted in different ways | Eliminate ambiguity and clarify the intent of specific sections |
| Rewrite applicable sections in plain language, improving flow, and addressing inconsistent use of terms within the guidance | Incorporate more plain language principles by using simple words and phrases, avoiding jargon, using terms consistently, and being concise |
The increased thresholds described above include the following:
| Area | Previous Threshold or Rate | New Threshold or Rate |
|---|---|---|
| Single Audit or Program Specific Audit | $750,000 | $1,000,000 |
| Type A threshold for entities expending awards from $1 million to $34 million | $750,000 | $1,000,000 |
| Equipment that may be retained, sold, or otherwise disposed of with no further responsibility to the federal agency | $5,000 | $10,000 |
| Unused supplies required to be sold at the end of a grant award period | $5,000 | $10,000 |
| De Minimis indirect rate | 10% | 15% |
| Amount of subawards recipients can apply to the indirect rate | $25,000 | $50,000 |
In addition, the revision updates the cost accounting standards and disclosure statement to remove the requirement to submit a DS-2 disclosure statement in support of an indirect rate.
These changes also clarify the allowability of certain costs, as well as improve grant announcements and notices of funding opportunities. The effective date for the final guidance is October 1, 2024. Federal agencies may elect to apply the final guidance to federal awards issued prior to October 1, 2024, but they are not required to do so. However, the effective date for the increase in the single audit threshold is not clear. Stay tuned for further updates.
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