As an administrator, you’re well aware that grants management can be a complex and frustrating exercise. Keeping your reporting on track while adhering to program-specific guidelines is a challenge unto itself, but on top of that, there’s always the ever-present Uniform Guidelines requirements to contend with.
These guidelines are dense, complicated, and not for the faint of heart. Ask the average grants manager and they’ll likely tell you it took years of dedicated work to master them. So with the recent news of the Office of Management and Budget (OMB) announcing new updates to Uniform Guidelines taking effect October 1, 2024, it’s likely to elicit a few understandable groans.
The good part? Some of these changes may make your day-to-day work easier. To help you gain a better grasp of these updates (and what effect they’ll have), we’ve outlined and summarized them below.
But first, let’s talk about why this Uniform Guidance update happened in the first place.
Why Uniform Guidance Requirements Changed
According to the OMB, the recent updates are all designed to help Uniform Guidance requirements achieve a particular set of goals:
- Improve stewardship of Federal funds
- Promote equitable access to programs and services
- Reduce administrative burden for agencies, applicants, and recipients
- Facilitate streamlined and effective oversight and implementation of Federal programs
In addition, a newly formed organization known as the Council of Federal Financial Assistance (COFFA) will oversee “ensuring that Federal agencies have the tools they need to deliver federal financial assistance programs in an efficient, effective, and equitable manner while also reducing administrative burdens on federal financial assistance applicants and recipients.”
In service to this mission, COFFA will begin standardizing Uniform Guidance training and processes. And to do this, they’ll be putting into effect several specific changes:
Increased Thresholds
In what’s sure to be a popular move, the de minimis for direct and indirect costs will be officially increased this year.
Here’s a more specific breakdown:
- For indirect costs, the new de minimis is now 15% (compared to 10% previously)
- For direct costs, it’s going up to $50K for each subrecipient (up from $25K)
- For equipment, the threshold has been raised to $10K per unit
- Likewise, supplies have gone up to $10K
- The maximum threshold for fixed amount subawards is now $500K (up from $250K)
Likewise, the proposed threshold for single audits is now $1M from its previous $750K, which should be good news for grantors looking to lighten their administrative burden.
Simpler Language
If you’ve ever found yourself wishing for a translator while trying to make sense of Uniform Guideline’s more confusing phrasing and naming conventions, they seem to have heard your concerns loud and clear: a move to make the guidelines’ language easier to understand is in the works. For example, the term non-federal entity will be replaced with the more reader-friendly recipient or subrecipient going forward, and vague categorizations like OPB designated government-wide system will fall away in favour of using the specific names of government systems (such as SAM.gov).
Stricter Mandatory Disclosure Timelines
With the OMB prioritizing issues like transparency and compliance, it’s unsurprising that timelines for mandatory disclosures (notifications of fraud investigations) are also being altered.
While these changes may seem insignificant on paper, they’ll end up affecting the timing of mandatory disclosures in a major way. In years past, it was understood that applicants, recipients, and subrecipients were only expected to disclose potential fraudulent activity once they had irrefutable proof. With these changes, they’ll be required to share information about the investigation as soon as any credible evidence enters the picture.
Conclusion
While some of these changes aim to reduce the confusion and complexity around regulatory guidelines (and remaining compliant in general), it’s still a lot of work for grants professionals to become fluent in the language of Uniform Guidance.
If you’re looking to simplify grants compliance, a digital grants management solution like Euna Grants makes it easy by centralizing all requirements in one place, allowing you to stay on top of changing standards and reduce compliance-related stress.
Ready to learn more? Book a demo today.
