Uniform Guidance | Final updates effective 1 October 2024
05/12/2024
The Office of Management and Budget (OMB) has finalised significant changes to the Guidance for Grants and Agreements, aimed at improving clarity, consistency, and compliance in managing US Federal grants and financial assistance.
The OMB Guidance for Financial Assistance (Uniform Guidance) issued to all Federal agencies for use across all United States Federal Grants is the first major revision since its establishment in 2013.
The OMB originally established the requirements for federal grants management in 2013 consolidating and superseding requirements from several guidance documents related to the Federal financial assistance management and implementation of the Single Audit Act.
The four objectives for the current revisions, effective 1 October 2024 are:
- incorporating statutory requirements and administrative priorities to ensure consistency with statutory authorities
- reducing agency and recipient burden that included increasing several monetary thresholds that have not been updated for a number of years
- clarifying sections that recipients or agencies have interpreted in difference ways
- rewriting applicable sections in plain language, improving flow and addressing inconsistent use of terms.
What is the impact?
Organisations should review the revised Uniform Guidance changes and determine if there are any impacts on their current federal awards. Changes that may impact organisations include the following:
- increased the Single Audit threshold from $750,000 to $1,000,000 (section 200.501)
- increased the threshold for determining Type A programs to $1m if the total annual expenditures of all federal programs for a non-federal entity are $34m or less. This was previously $25 million or less (section 200.518)
- raised the de minimis rate non-federal entities can use for indirect costs from 10% to 15%. Recipients and subrecipients that do not have a current federal negotiated indirect cost rate may elect to charge a de minimis rate of up to 15% of modified total direct costs when this change goes into effect
- revised the threshold value for equipment from $5,000 to $10,000
- inclusion of a requirement that recipient and sub-recipient internal controls include cybersecurity and other measures to safeguard information
- changes to procurement standards.
SW are education specialists
Our approach to Uniform Guidance audits offers best practice expertise in a practical and commercial manner that is delivered using senior personnel with significant educational sector experience.
We have worked with 35 of the 41 major Australian universities and have extensive experience in assisting education providers with an appropriate audit of US Government sourced funds as required by the OMB Guidance for Federal Financial Assistance.
Our experts can assist with:
- quality expertise and industry insight in compliance with OMB’s Guidance for Federal Financial Assistance reporting requirements
- assessment of internal controls to ensure that research grants are managed in compliance with legislative/regulatory requirements
- direct link to Guidance for Federal Financial Assistance experts in the US, and
- tailored and collaborative audit methodology.
