OMB Finalizes Changes to Uniform Guidance
Section: Around the Nation

The US Office of Management and Budget has finalized proposed changes to Title 2 of the Code of Federal Regulations (CFR) Subtitle A - OMB Guidance for Grants and Agreements commonly referred to as the Uniform Guidance. The changes are in a number of areas specifically geared toward aligning with the work already underway as part of the President’s Management Agenda to: standardize the grants management business processes and data, build shared IT infrastructure, manage risk; and achieve program goals and objectives.
NASACT submitted a comment letter earlier this year expressing concerns about how performance measurement requirements and testing procedures would be brought into the Compliance Supplement and be audited. NASACT also suggested that OMB provide a clear timeline of effective dates to minimize confusion that could result if there is a change of Administration following upcoming elections.
OMB accepted many of NASACT’s suggestions, particularly clarifications regarding the use of “must” and “may.”
OMB is including revisions to clarify the following: The meaning of the words ‘‘must’’ and ‘‘may’’ as they pertain to requirements; applicability and documentation requirements when a non-federal entity elects to charge the de minimis indirect cost rate of MTDC; PTE responsibilities related to indirect cost rates and audits; and applicability of 2 CFR to FAR based contracts. These proposed revisions are intended to improve clarity and reduce recipient burden by providing guidance on implementing 2 CFR.