OMB Proposes Revisions to the Uniform Guidance

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.

A tracked-changes version showing the proposed changes to the Uniform Guidance can be accessed here. OMB is currently seeking public comment on the proposed rule. Comments are due by March 23, 2020, and can be submitted via Regulations.gov here.

Please join us for a webinar to discuss the proposed revisions and potential impacts for CAAs.

Webinar: Proposed Revisions
to the Uniform Guidance

Date: Thursday, February 20, 2020
Time: 1:00 pm - 2:00 pm EST

This News Flash is part of the Community Services Block Grant (CSBG) Legal Training and Technical Assistance (T/TA) Center. It was created by Community Action Program Legal Services, Inc. (CAPLAW) in the performance of the U.S. Department of Health and Human Services, Administration for Children and Families, Office of Community Services Cooperative Agreement – Grant Award Number 90ET0467-03. Any opinion, findings, conclusions, or recommendations expressed in this material are those of the author(s) and do not necessarily reflect the views of the U.S. Department of Health and Human Services, Administration for Children and Families.

The contents of this news flash are intended to convey general information only and do not constitute legal advice. Any communication through this publication or through CAPLAW’s website does not constitute or create an attorney-client relationship. If you need legal advice, please contact CAPLAW or another attorney directly.