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Revisions to Uniform Guidance

21 Sep 2020 1:49 PM | Anonymous

On August 13, 2020, the Office of Management and Budget (OMB) issued amendments to the Uniform Guidance. Nonprofits receiving funds from the U.S. government should review the amendments carefully and the impact these revisions may have on administrating U.S. government funds. Below are summaries of several of the amendments made.

  • Use Exceptions (2 C.F.R. § 200.102). Recognizing that the Uniform Guidance is not a one-size-fits-all approach, this provision grants agencies the flexibility to make exceptions to the Uniform Guidance requirements. This provision now "strongly encourages Federal awarding agencies to add or remove requirements [in the Uniform Guidance] by applying a risk-based, data-driven framework to alleviate select compliance requirements and hold recipients accountable for good performance”.  
  • Termination (2 C.F.R. 200.340). This provision now allows an agency to terminate federal awards when the program goals or agency priorities are no longer being met. 
  • De Minimis Rate (2 C.F.R. § 200.414(f)). The use of the de minimis rate of 10 percent was expanded to include not just organizations that have never obtained a NICRA but also those organizations that may have had NICRAs in the past but whose rates may now be expired. This change also allows organizations who may have previously had a NICRA but did not want to continue with the exorbitant expense of establishing a new NICRA.
  • Publication of NICRAs (2 C.F.R. § 200.414(h)). This provision requires that certain information relating to NICRAs be collected and displayed publicly. However, to avoid publishing proprietary information, OMB limits the type of information that should be published to the indirect negotiated rate, the distribution base, and the rate type.
  • Domestic Preference for Purchasing (2 C.F.R. § 200.322). This new provision encourages recipients to "maximize use of goods, products, and materials produced in the United States". 
  • Procurement Methods (2 C.F.R. § 200.320). This provision increased the micro-purchase threshold from $3,500 to $10,000 and the simplified acquisition threshold from $150,000 to $250,000. 
  • Project Close-out (2 C.F.R. § 200.344). This provision revised the time period from 90 days to 120 days for recipients to submit closeout reports and liquidate all financial obligations. In addition, agencies are required to now report any failure on the part of a recipient organization to submit final closeout reports as a "failure to comply with the terms and conditions of the award".

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