Section: Washington Update

Last week, proposed revisions to the U.S. Office of Management and Budget’s Guidance on Grants and Agreements were officially published for comment in the Federal Register. A redline version of the proposed changes can be viewed here.
NASACT Members: Provide Your Input
NASACT will be preparing an association response. Please send your comments to Cornelia Chebinou by November 17, 2023.  Additionally, if you are sending comments directly to OMB, please also send us a copy.  Please note that while it is important to provide comments and insights to the questions posed in the document, it is also extremely beneficial to also provide commentary on any other areas of OMB’s guidance on grants and agreements that you believe could use clarification and/or amendment. 
Proposed Revisions
The proposed revisions are in a number of areas including:
  • Part 1 (About Title 2 of the Code of Federal Regulations and Subtitle A)
  • Part 25 (Universal 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 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards) 

Although the proposed revisions cover many areas, there are a few items of note in the proposal:
  • Raises the single audit threshold from $750,000 to $ 1 million.
  • Raises the de minimus indirect cost rate from 10% to 15%.
  • Removes the requirement that indirect cost rates be available on a governmental website.
  • Uses the term recipient and subrecipient except in areas where a specific provision applies to an entity that is not a federal entity.
  • Raises equipment and supply thresholds from $5,000 to $10,000.
  • Modifies and expands many definitions such as period of performance and questioned costs
  • Modifies the definition of “Modified Total Direct Costs” to exclude subaward costs above $50,000.
  • Removes prior written approval for 10 items of cost.
  • Revises areas of the cost principals including clarification of pension costs.
  • Revises the template text for a Notice of Funding Opportunity (NOFO). 

OMB is also seeking comment on several areas that could be modified in future revisions including:
  • Audit requirements for for-profit entities.
  • Additional guidance on loans and loan guarantees.
  • Automatic adjustments for certain thresholds.
  • Amendments to indirect costs.
  • Expanding audit guidance to address “proper perspective.” 
  • How to Submit Comments to OMB
Comments on this proposal must be submitted electronically before the comment closing date of 12/04/2023 to In submitting comments, please search for recent submissions by OMB to find docket OMB–2023–0017, which includes the full text of the proposed revisions and submit comments there. Please provide clarity as to the section of the guidance that each comment is referencing by beginning each comment with the section number in brackets. For example, if the comment is on 2 CFR 200.1 include the following before the comment [200.1]. The public comments received by OMB will be posted at and will be a matter of public record.