On December 19, 2014, the Office of Management and Budget (OMB) and the Department of Defense (DoD) along with other Federal grant making agencies issued a joint interim final rule which implemented OMB’s Uniform Guidance for Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200), also referred to as the “Uniform Guidance,” which was published in the Federal Register on December 26, 2013. The Department of Defense’s implementation of the new guidance in 2 CFR Part 1103 was done on an interim basis while the Department finalizes its revisions to the Department of Defense Grants and Agreements Regulations (DoDGARs) over the next several months. The DoDGARs will establish Department-wide standard award terms and conditions which will apply to all DoD Federal assistance awards made after December 26, 2014, the effective date of the joint interim final rule.
The much anticipated new grants guidance was the result of OMB’s efforts to streamline existing regulatory guidance for Federal financial assistance with two main goals. The first goal focused on reducing administrative burden by eliminating duplicative and conflicting guidance, promoting an emphasis on performance versus compliance, and providing for a more consistent treatment of costs. The second goal focused on reducing fraud, waste, and abuse by strengthening oversight, targeting audit requirements, and limiting allowable costs. The Council on Financial Assistance Reform (CoFAR) which is represented by Federal agencies, recipients, and other stakeholders in the grants community took the lead in developing the Uniform Guidance and is responsible for ensuring its successful Agency implementation. CoFAR’s web-site which can be found at www.cfo.gov provides a wealth of information regarding its grants reform efforts to date as well as things on the horizon. CoFAR advises OMB on policy matters related to grants reform.
The Uniform Guidance includes over 60 regulatory changes to Federal grants management. Some of the more significant changes are highlighted below.
- Federal Funding Announcements (FFO) must be posted 60 days in advance of the application deadline.
- Recipient mandatory written disclosure of any potential conflict of interest in the management of the grant to the awarding entity.
- Recipients must implement and maintain effective internal controls.
- The simplified acquisition threshold is increased to $150,000.
- Entities are allowed to extend negotiated indirect cost rates for up to four years.
- New recipients have the option to accept a negotiated indirect cost rate not to exceed a deminis flat rate at 10 percent of modified total direct costs (MTDC) to be used for all federal awards.
- The single audit threshold increased from $500,000 to $750,000.
- Roles and expectations for pass-through entities conducting oversight of subrecipients are better clarified with a more robust system of oversight and monitoring.
OEA will post updates as they become available including links to OMB and DoD guidance in addition to OMB webinars, to the extent available. You can also access the Grants Management tab via the main Grants tab on our Home Page for additional information or references to other helpful resources.