OMB Proposed Uniform Guidance Changes

February 6, 2020

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On January 22, 2020, the Office of Management and Budget (OMB) issued proposed revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). This is the first major substantive revision to the Uniform Guidance since 2014.

FTLF attorneys are conducting a thorough examination of the proposed changes to share our observations on the key revisions, highlight particularly impactful changes, and discuss the potential implications for grantees. In the interim, we have identified a number of noteworthy changes through an initial review, which are listed below. For more detailed descriptions of these changes with specific references, read our full client alert.

Comments are due on Monday, March 23, 2020: We encourage all grant recipients to review the proposed changes and submit comments to OMB. All comments must be submitted electronically and you can comment directly on the Federal Register website here or through

Proposed OMB Revisions: Initial Review Highlights

Among other suggested changes, the OMB revisions include the following:

  • Bar on awarding agencies incorporating non-binding guidance into the terms and conditions of a federal award;
  • Updated definitions of "budget period" and "project period";
  • Expanded authority for agencies to terminate awards on the basis of altered program policy goals;
  • Availability of the de minimis indirect rate to all grant recipients (even if they previously had a formal indirect rate agreement);
  • More time for final report submission and liquidation of obligations for direct recipients (no change for subawards);
  • Domestic item preference for procurements under federal awards;
  • “Never Contract with the Enemy” requirements for certain recipients engaged in international work;
  • Mandatory listing of grantee "parent" or "subsidiary" entities in the System for Award Management (SAM);
  • Consideration of FAPIIS data for a grant applicant’s parent or subsidiary;
  • Increased subaward reporting threshold under the Federal Financial Assistance Transparency Act (FFATA); and
  • Prohibition against purchasing / using telecommunication equipment provided by certain foreign entities.

For more detailed information on these proposed changes, read the full client alert on our website.

Target Audience

  • CEOs / Directors
  • CFOs
  • Fiscal Staff
  • Compliance Directors
  • Grants Management Staff
  • Anyone who needs to stay apprised of potential changes in the federal grants regulatory landscape
Course summary
Available credit: 
  • 1.00 Certificate of Attendance
Course opens: 
Course expires: 
Event starts: 
02/06/2020 - 1:00pm EST
Event ends: 
02/06/2020 - 2:15pm EST


A Partner with the firm in the Federal Grants and Health Law practice groups, Scott advises clients on matters of federal grant law, government contract law, and health care law.  Scott assists clients with the myriad requirements that apply upon acceptance of federal grant funding, including the administrative requirements and cost principles established in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), the Office of Management and Budget (OMB) Circulars that preceded the Uniform Guidance, and program-specific statutory and regulatory funding conditions. [Full Bio]


Serving as Managing Partner of the firm since 2003, and a member of the Health Law and Federal Grants practices since 1992, Ted is a national authority in the area of federal grants, particularly in the health and community service spheres. He advises clients on all aspects of program requirements, including issues such as cost-based reimbursement, governance, grant administration, cost reporting, and administrative issues and routinely handles challenging issues such as government audits, internal investigations, and litigation. Ted's priority is to help each organization carry out its mission by offering practical, down-to-earth counsel and to ensure that legal challenges do not distract from that focus. [Full Bio]

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