(Recorded Webinar) OMB Proposed Uniform Guidance Changes
On September 22, 2023, 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). The proposed rule, published on October 5, 2023, is detailed in the Federal Register.
Comments are due by December 4, 2023. 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 Regulations.gov.
FTLF attorneys are conducting a thorough examination of the proposed changes. Join us for this industry update to share our observations on the key revisions, highlight particularly impactful changes, and discuss the potential implications for grantees.
Proposed OMB Revisions: Initial Review Highlights
Among other changes, the OMB proposed revisions include the following:
- Increasing Single Audit Act audit threshold from threshold $750,000 to $1 million
- Increasing the amount of “subaward” costs that can be counted within the MTDC base from $25,000 to $50,000 and increasing the de minimis indirect cost rate to 15 percent over MTDC
- Removing the “simplified acquisition threshold” cap for fixed amount subawards that is currently in place
- Clarifications to applicability and terminology
- Relaxation or clarification of prior approval requirements
- CEOs / Directors
- Fiscal Staff
- Compliance Directors
- Grants Management Staff
- Anyone who needs to stay apprised of potential changes in the federal grants regulatory landscape
After this webinar, you will be able to:
- Understand the proposed changes in the Uniform Guidance
- Determine how the potential revisions may impact your organization
- Decide if you or your organization will submit comments to OMB
Nicole Bacon, a Partner at the firm, works in the Federal Grants, Litigation, and Health Care practice groups. Nicole offers her clients specialized guidance in compliance with federal grant law including specific programmatic requirements as well as the Uniform Administrative Requirements, Cost Principles and Audit Requirements of Federal Awards. Nicole represents a variety of community-based organizations, before State and Federal courts as well as administrative bodies. [Full Bio]
Phillip Escoriaza is Senior Counsel in the firm’s Federal Grants and Health Care practice groups. A native of Puerto Rico, Phillip’s bilingual, nationwide practice serves non-profit organizations, municipalities, local government agencies, and other federal grantees. Prior to joining Feldesman Tucker, Phillip ran a practice from San Juan which spanned corporate, business, public policy, government and contract law, and included contested matters and appeals before state and federal courts. [Full Bio]
Scott Sheffler is a Partner with the firm in the Federal Grants and Health Law practice groups. He 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]
Ted Waters has served as Managing Partner of the firm since 2003, and as a member of the Health Care 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. His 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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