Uniform Guidance (2 CFR 200) Update
The Office of Management and Budget (OMB) has announced updates to the Uniform Guidance, 2 CFR 200, which are effective as of October 1, 2024. The Uniform Guidance is a set of federal regulations that govern the administration of federally funded financial assistance awards (i.e., grants and cooperative agreements). The revisions aim to streamline and enhance federal grant management and promote greater efficiency and accountability in the administration of federal funds. Key changes include updated cost principles, changes to prior approval requests, and enhanced audit requirements.
The Office of Sponsored Projects (OSP) is working with other GW stakeholders to update processes in line with the updates. Federal agencies are actively working on implementation. Some have posted accompanying agency regulation, guidance, policies, and/or terms and conditions updates to reflect these changes. In addition, OSP expects updates to be incorporated directly into new awards.
Highlighted Changes
Equipment and Supply Threshold Changes
- 2 CFR 200.313: Equipment threshold increased from equaling or exceeding $5,000 to $10,000.
- 2 CFR 200.314: Supplies classified as an acquisition for less than $10,000.
- GW Guidance: Updated guidance will be provided in time for GW's FY26 effective date, July 01, 2025.
Facilities and Administrative Costs/Indirect Costs Definition
- OMB has removed the use of the term “Facilities and Administrative (F&A) cost” from the definition of Indirect Cost; however, Uniform Guidance and many federal agencies continue to use this term.
- GW Guidance: While these terms will likely continue to be used interchangeably for some time, OSP will move towards the use of Indirect Costs in all future policy updates.
Modified Total Direct Cost (MTDC) Change
- The definition of Modified Total Direct Cost (MTDC) is updated to allow indirect cost recovery for each subaward up to $50,000.
- This change is not applicable to recipient institutions until the definition is reflected in the institution’s Negotiated Indirect Cost Rate Agreement (NICRA).
- GW Guidance: GW cannot implement the $50,000 threshold in budgeting until after our next NICRA is approved. The GW NICRA is currently effective through FY2025.
De Minimis Rate for Indirect Costs for Subrecipients
- 2 CFR 200.414 allows for the application of a 15% indirect cost rate for entities that do not have a Negotiated Indirect Cost Rate Agreement.
- GW Guidance: Beginning on October 1, 2024, OSP will approve subaward budgets in proposals with indirect costs for eligible entities at the 15% rate. This will not automatically apply to proposals that are submitted before October 1.
Resources
The full text of the Uniform Guidance revision is available in the Federal Register. If you have any questions about the upcoming changes, please submit your questions via the OSP Help Desk form.