Grants Uniform Guidance Updates — What you need to know
Written by: Ruth Famojuro
Grants policy fanatics (like me) greeted the arrival of the proposed changes to 2 CFR with great excitement. After all, the last time something this big happened in Federal grants was in 2013 when the Uniform Guidance was first issued.
However, if the idea of reading 44 pages of three columns of tiny print (the equivalent of 186 pages at normal print, double-spaced) isn’t your idea of a fun weekend, we’ve distilled the most salient points so you can enjoy your time instead!
- Regulations can be confusing. Recipients were confused by existing definitions within 2 CFR, so OMB proposed some clarifying updates.
- Not all regulations are consistent. Because the procurement thresholds in the current 2 CFR 200 are different than other regulations, they have been updated throughout the guidance, and some of the procurement standards have been made more flexible for procurements that fall beneath the thresholds.
- Easier is better. The current 2 CFR 200 only allows recipients who do not yet have a negotiated indirect cost rate to use the de minimis rate of 10% of modified total direct costs. Some recipients already had a negotiated rate but wished for the greener grass on the de minimis side of the fence. So, OMB essentially said, “Sure. Why not?” for many recipients. This will make things easier for small recipients for whom maintenance of a rate is time-consuming and expensive. And, it reduces the burden for Federal agencies that negotiate and approve the rates.
- Isn’t fairness better? The proposed changes aim to increase the consistency of merit review processes across all Federal discretionary awards.
- Risk is bad, and planning is good, right? Well, that’s debatable. But many, many, many acts and orders and memos provide directions on assessing risk and planning performance. OMB tried to add some consistency in the existing guidance here.
- Technology marches on. As the Federal Government creates new systems and consolidates and simplifies the user experience for applicants and awarding personnel, websites, systems, and terminology change. There are some proposed updates related to SAM.gov, the retirement of the CFDA, as well as other websites and system changes.
- Sometimes, you must state the obvious. The newly proposed Part 183, Never Contract with the Enemy, is exactly that. It only applies to awards outside of the United States that exceed $50,000, so it will not impact most awards.
If these changes affect you, you may want to provide comments on the proposed regulations, either supportive or constructive.
- Access a “tracked changes” version of the proposed changes to the current Uniform Guidance at https://www.performance.gov/CAP/innovation-sessions/Grants-CAP-Goal-Proposed-2CFR-Revision1.pdf,
- Read the proposed Uniform Guidance in its entirety at https://www.federalregister.gov/documents/2020/01/22/2019-28524/guidance-for-grants-and-agreements
- Submit comments about the proposed changes before March 23, 2020, at https://www.regulations.gov/document?D=OMB_FRDOC_0001-0262.
We’ll be covering these changes and more in detail in our Federal Grants Update 2020 course, https://www.managementconcepts.com/course/id/2020, throughout the year. Once finalized by OMB, these changes will be incorporated into all Management Concepts Grants courses.
