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OMB Proposes Revisions to the Uniform Guidance

2020

On January 22, 2020, the federal Office of Management and Budget (OMB) announced proposed revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 C.F.R. Part 200, that would affect all federal grant recipients, including Community Action Agencies (CAAs). If implemented, the proposed revisions would make several key changes to the Uniform Guidance, including:

  • Giving more organizations the option of adopting the 10% de minimus rate for indirect cost recovery;
  • Allowing organizations to request higher micropurchase thresholds for procurement beyond the current $10,000 limit;
  • Clarifying the requirement that pass-through entities must recognize and pay a subrecipient’s indirect costs, and specifying options for doing so;
  • Revising definitions in an attempt to further standardize the grants management business process and data; and
  • Shifting the balance between compliance and performance to provide federal agencies with the opportunity to streamline burdensome compliance requirements for programs that demonstrate results.

Presented on: February 20, 2020
Presented by: Caroline F. Kelley, Esq., Veronica Zhang, Esq. and Allison Ma’luf, Esq., CAPLAW

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