White House OMB releases final revisions federal Uniform Guidance (2 CFR Part 200)

Key Takeaways

On April 4, the White House Office of Management and Budget (OMB) released its final revisions to the federal Uniform Guidance (2 CFR Part 200) that outline compliance and reporting requirements for federal financial assistance, such as grants and loans. 

Why do counties care?

As the recipient of billions of federal dollars each fiscal year, counties must comply with these regulations when investing, reporting and auditing federal funds. However, compliance with the Uniform Guidance can be burdensome, especially for smaller, often rural, counties.

• Example: Counties must comply with the procurement policies detailed in the federal uniform guidance wheninvesting ARPA State and Local Fiscal Recovery Funds (SLFRF) 

How did we get here?

In October 2023 OMB unveiled proposed revisions following a Request for Information (RFI) published in February 2023 seeking feedback from stakeholders on the federal Uniform Guidance generally. 

• Read NACo’s comments in partnership with the Government Finance Officers Association (GFOA), National League of Cities (NLC) and the National Institute of Government Purchasing (NIGP) here.

Prior to these final revisions, federal Uniform Guidance has been implemented through an interim final rule published in December 2014 that was further revised in 2020. 

Key highlights of finalized uniform guidance

These finalized revisions to federal Uniform Guidance are intended to reduce administrative burden on both federal grant awarding agencies and grant recipients through streamlining the process and to reduce barriers of entry to federal grants and other forms of financial assistance. 

Key highlights include: 

• Revised Notice of Funding Opportunity (NOFO) requirements for federal agencies to simplify and increase accessibility and clarity for applicants, including a revised NOFO template
• Clarification and plain language revisions to certain terms and definitions so that they are uniformly interpreted, such as the term “federal financial assistance” 
• Increase of the Single Audit threshold from $750,000 to $1 million and the threshold for determining “equipment” 

Next steps

OMB issued an implementation guide for federal agencies to put these revisions into practice by the start of Fiscal Year (FY) 2025 or  October 1, 2024. 

• This includes a requirement that federal agencies update and improve the new Federal Program Inventory (FPI) tool where counties and other non-Federal entities can locate comprehensive information about federal grant, loan and financial assistance opportunities 

Federal agencies have until May 15 to submit their plan for implementation. 

A full NACo analysis of the revised uniform guidance is forthcoming.