TIP LINE – EDITION 24 – Proposed Uniform Guidance Updates
In this week’s Capital Edge Tip Line, CEO Chad Braley discusses OMB’s proposed revisions to 2 CFR 200 (Uniform Guidance) and what they may mean for organizations managing federal financial assistance awards.
Key updates from this week’s Tip Line
What’s happening? At a high level, the proposed changes are intended to improve transparency, accountability, and oversight while clarifying regulatory requirements and reducing administrative burden for recipients.
- Greater flexibility to suspend, stop work, or terminate awards
- The proposed language challenges the assumption that federal financial assistance awards remain stable if recipients are performing and complying with regulations.
- Pass-through entities face increased scrutiny on subrecipient oversight
- Recipients may see higher expectations around monitoring and documenting subrecipient performance and compliance.
- Emphasis on cost-reimbursement style monitoring
- Proposed language introduces greater focus on cost-reimbursement-style monitoring of subawards, while placing less emphasis on fixed-amount awards.
- Expanded prior approval requirements
- Prior approval may be required for certain costs, including publication, conferences, fundraising, advertising, and other activities.
How contractors can stay ahead: Contractors should begin to inventory federal awards, subawards, and grant-funded programs to identify where the proposed changes may have the greatest impact, reassess subrecipient monitoring procedures and supporting documentation, and evaluate funding concentration risks and consider contingency plans for critical programs.
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