Meet Dan Durst.  Dan has 12 years of experience in various accounting and compliance issues related to Federal government contracts, grants, and cooperative agreements. Dan’s areas of expertise include Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal awards to non-Federal entities (Uniform Guidance), and Federal Acquisition Regulation (FAR). Dan is also well-versed in various levels of audit support including Business System Reviews, Single Audit, and Inspector General audits.

More about Dan...


In addition to being passionate about Federal Grants compliance, Dan also contributes to thought leadership publications, articles and provides regular updates on new and proposed changes through public and private training and virtual updates. Connect with Dan for the latest and see some of the resources he has published or contributes to.

Want to Learn More Regarding Federal Grants Compliance?

BREAKING: Federal Grants Compliance Updates​

Our Federal Grants Compliance Expert Dan Durst covers the top issues currently on the minds of Federal Grant recipients. Commentary on OMB’s Proposed Updates to Uniform Guidance – 2 CFR 200.

Federal Grants Compliance Training

Federal Grants Compliance Resources

Latest Questions Being Asked About Federal Grants Compliance

On August 13, 2020, OMB published Final Guidance to revise Uniform Guidance for the first time since its initial release date in 2014. These revisions to the guidance are effective November 12, 2020, except for the amendments to §§200.216 (Prohibition on certain telecommunication and video surveillance services or equipment) and 200.340 (Termination), which are effective on August 13, 2020.

The following two provisions are most impactful to recipients:

1. §200.322 Domestic preferences for procurements. This new requirement emphasizes that an organization to the greatest extent practicable under a Federal award, provide a preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States (including but not limited to iron, aluminum, steel, cement, and other manufactured products).

2. §200.320 Methods of procurement to be followed. Organizations may be eligible for a Micro-Purchase Threshold up to $50,000 if they meet the criteria set forth in this revised section.

Auditors are likely to have an increased focus on the adequacy of organizational policies and procedures due to the inclusion of an enhanced Internal Controls part in the August 2019 Compliance Supplement by OMB. The Compliance Supplement is a document that identifies existing important compliance requirements that the Federal Government expects to be considered as part of an audit required by the Single Audit Act Amendments of 1996 and 2 CFR part 200, subpart F. Part 6 titled “Internal Controls” in the 2019 Compliance Supplement contains illustrative control activities that an auditor can expect to find in an adequate set of policies and procedures. This new set of information that is being furnished to auditors will act as a benchmark against which auditee organizations may be measured.

On June 18th, 2020 OMB Issued Memorandum M-20-26 which rescinded M-20-17 and provided an extension for two of the flexibilities through September 30, 2020. When addressing the allowability of salaries and other project activities the memorandum said the following regarding the PPP loan and other CARES Act funding:

“Under this flexibility, payroll costs paid with the Paycheck Protection Program (PPP) loans or any other Federal CARES Act programs must not be also charged to current Federal awards as it would  result in the Federal government paying for the same expenditures twice.”

Yes, Fund payments are considered to be federal financial assistance subject to the Single Audit Act (31 U.S.C. §§ 7501-7507) and the related provisions of the Uniform Guidance, 2 C.F.R. § 200.303 regarding internal controls, §§ 200.330 through 200.332 regarding subrecipient monitoring and management, and subpart F regarding audit requirements. The CFDA number assigned to the Fund is 21.019.

Downloadable Datasheets

Scroll to Top
Skip to content