DATE: October 10, 2024
SUBJECT: Revisions to 2 CFR Subtitle A, Office of Management and Budget Guidance for Federal Financial Assistance Effective October 1, 2024
SUMMARY: The Office of Management and Budget’s (OMB) revised several parts of the OMB Guidance for Federal Financial Assistance located in Title 2 of the Code of Federal Regulations, Subtitle A effective October 1, 2024.
These revisions provide clarity and updated guidance to Federal agencies regarding the consistent and efficient use of Federal financial assistance. The revisions include the following Parts: Part 1 (About Title 2 of the Code of Federal Regulations and Subtitle A); Part 25 (Unique Entity Identifier and System for Award Management); Part 170 (Reporting Subaward and Executive Compensation Information), Part 175 (Award Term for Trafficking in Persons); Part 180 (OMB Guidelines to Agencies on Government-Wide Debarment and Suspension (Non-procurement); Part 182 (Government-Wide Requirements for Drug-Free Workplace (Financial Assistance)); Part 183 (Never Contract with the Enemy); Part 184 (Buy America Preferences for Infrastructure Projects); and Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards).
OMB's revisions to several parts of subtitle A of 2 CFR include: (1) incorporating statutory requirements and administration priorities; (2) reducing agency and recipient burden; (3) clarifying sections that recipients or agencies have interpreted in different ways; and (4) rewriting applicable sections in plain language, improving flow, and addressing inconsistent use of terms.
Some of OMB’s revisions include increasing several monetary thresholds that have not been updated for many years, such as: the single audit threshold from $750,000 to $1,000,000; the fair market value threshold for equipment and supplies from $5,000 to $10,000; the subaward threshold in the MTDC for indirect costs from $25,000 to $50,000; and the indirect cost di minimis rate from 10% to 15%. Other revisions support reducing administrative burden, such as the complete revision to the template text for a Notice of Funding Opportunity (NOFO) located in Appendix I of the Uniform Guidance in part 200.
As a result of these changes DOE updated its Guide to Financial Assistance (https://www.energy.gov/management/financial-assistance), updated its NOFO and Award templates, and issued a class deviation (https://www.energy.gov/management/policy-flashes) while in the process of updating its Financial Assistance Regulations at 2 CFR 910. Questions concerning the policy flash should be directed to the Contract and Financial Assistance Policy Division, Office of Policy in the Office of Acquisition Management at DOE_oapmpolicy@hq.doe.gov.