Alert
Clarification on Uniform Guidance Revision Usage
Federal agencies, recipients of federal assistance, and auditors have been grappling with which version of the Office of Management and Budget (OMB) Uniform Guidance 2 CFR 200 (2 CFR 200) should be followed on awards that don’t explicitly state the use of either pre- or post-October 1, 2024, guidance.
The Council of Federal Financial Assistance (COFFA) recently provided much needed clarity on certain implementation aspects of the 2024 Revisions to 2 CFR 200, which are applicable to new awards issued after October 1, 2024. COFFA’s memo provides further implementation guidance and flexibilities.
Gain insights into COFFA’s memo that can help your agency overcome 2 CFR 200 implementation challenges and maintain reporting accuracy and compliance.
2024 Revisions Implementation
In its memo, COFFA states that unless otherwise indicated in federal statutes, agency regulations, or federal awards, the 2024 Revisions are applicable as follows:
- New federal awards issued on or after October 1, 2024. If the award is silent on which version of the 2 CFR 200 is applicable, recipients should apply the 2024 Revisions.
- Existing awards issued before October 1, 2024. Unless an amendment to the award has been issued, recipients should continue to apply the previous version of 2 CFR 200.
- Amendments issued on or after October 1, 2024. If the amendment doesn’t explicitly say to use the 2024 Revisions, recipients should continue to apply the previous version of 2 CFR 200.
- Subawards. Pass-through entities with federal awards that have been amended for the 2024 Revisions are required to amend existing subawards to apply the 2024 Revisions. If the federal award hasn’t been amended, then the previous version of 2 CFR 200 will continue to apply to subawards.
Most federal agencies have begun adoption of the 2024 Revisions to their agency codification which are typically located in Title 2 Subtitle B.
One exception is the Department of Health and Human Services (DHHS), which has adopted the 2024 Revisions with a limited number of provisions effective as of October 1, 2024, and the remainder of the provisions effective on October 1, 2025.
Flexibilities for Existing Awards
OMB is providing two exceptions to recipients of federal assistance in cases where existing awards are following the previous version of 2 CFR 200, if permitted by the awarding agency:
- Equipment and unused supplies threshold. All recipients of active and expired federal awards and subawards can use the revised equipment threshold of $10,000.
- Procurement standards for Tribes. Effective as of the issuance of this memo, all new procurements initiated by Tribes can follow their own procurement standards.
For only these exceptions, federal agencies may amend the applicable requirements through written notice, which can include e-mails, updating website information or other forms of communication, or upon written approval by a request from the recipient. This simplifies the process for these two requirements, as individual award modifications wouldn’t be required.
Administrative Exceptions for Disaster Relief
To create consistency across the federal government, COFFA has provided a list of common exceptions that federal agencies have previously granted following emergencies and major disasters. Federal agencies can grant these exceptions on a case-by-case basis to recipients that fall within geographical areas declared as emergencies or major disasters under the Stafford Act, except when prohibited by law or if other approval is required by the OMB.
Common exceptions include:
- No cost extensions on expiring awards
- Abbreviated non-competitive continuation requests
- Continuation of allowability of salaries and other project activities, within the recipient’s policy of paying salaries and other costs using federal and non-federal funding sources
- Allowability of costs not normally chargeable to awards, such as cancellation of events, travel, and other activities
- Waiving prior approval requirements of certain costs
- Extension of financial, performance, and other reporting up to three months beyond the due date
- Extension of currently approved indirect cost rates for an additional year
- Extension of closeout deadline up to one year after the award expires
- Cognizant or oversight agencies can provide extension of single audit report submission deadline
Increased Single Audit Thresholds
COFFA has clarified that the increased thresholds for single audits to $1,000,000 applies to non-federal entities’ fiscal years beginning on or after October 1, 2024.
COFFA FAQ Updates
COFFA has also issued an updated set of frequently asked questions for the 2024 Revisions. The previous FAQs have been archived and shouldn’t be considered applicable to the 2024 guidance.
If your organization is relying on prior FAQ guidance, review the updated guidance as many of the old FAQs have been removed, modified, or are now directly included in 2 CFR 200 as part of the 2024 Revisions.
There are also 12 new questions that have been added to the document.
We’re Here to Help
To Learn more about COFFA’s memo and how it can impact your organization or Tribe, contact your Moss Adams professional.