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Updates to OMB Guidance for Federal Financial Assistance: Key Changes and Implications
The Office of Management and Budget (OMB) has issued a Final Rule that significantly revises the Uniform Guidance for grants, cooperative agreements, and other federal financial assistance. The revisions aim to streamline and clarify grant rules, improve management, transparency, and oversight of federal financial assistance. Agencies must implement the Final Rule by October 1, 2024, with the option to apply it as early as June 21, 2024.
Highlighted changes include clarifications on Unique Entity Identifier requirements, alignment with the Trafficking Victims Protection Act, additional evidence for debarment decisions, and updates to the Mandatory Disclosure Rule. The Final Rule also introduces changes to fixed amount awards, post-award sourcing requirements, cybersecurity internal controls, procurement standards, and threshold increases for equipment and supplies retention.
These changes may help reduce burdens on recipients, subrecipients, and contractors under federal assistance awards. With the influx of federal awards from various acts, it is crucial for recipients to monitor their awards closely to understand specific compliance obligations. Crowell will continue to monitor and report on developments as agencies implement the new OMB Guidance for Federal Financial Assistance.
