White House OMB releases final revisions federal Uniform Guidance (2 CFR Part 200)
Author
Paige Mellerio
Upcoming Events
Related News
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.
Webinar
ARP State and Local Fiscal Recovery Fund Update: Treasury Compliance and Reporting Requirements
The U.S. Department of Treasury recently released reporting and compliance guidance for the State and Local Fiscal Recovery Fund (Recovery Fund). The Recovery Fund, authorized under the American Rescue Plan Act, provides $65.1 billion in direct and flexible aid to every county in America as well as offers opportunities for crucial investments in local communities. Join NACo for a webinar where participants will hear an overview of the new reporting guidance and how counties can ensure they are complying with these new guidelines.
Related News
NACo urges adequate FY 2027 Census Bureau funding to support the 2030 Census
NACo urges Congress to fully fund the U.S. Census Bureau in FY 2027, consistent with the administration’s budget request, to support 2030 Census preparation.
Treasury publishes new Do Not Pay matching program notice; NACo evaluating for comment
On May 18, the U.S. Department of the Treasury (Treasury) published a Federal Register notice establishing a new computer matching program under the Privacy Act of 1974. The notice authorizes Treasury to compare records held by about 40 of its programs against the Do Not Pay (DNP) Working System, a centralized verification portal operated by Treasury’s Bureau of the Fiscal Service. NACo will be submitting comments.
OMB proposes major overhaul of federal grant rules
On May 29, the U.S. Office of Management and Budget (OMB), in coordination with all federal grantmaking agencies, published a proposed rule in the Federal Register rewriting 2 Code of Federal Regulations (CFR) Part 200 which is commonly referred to as Uniform Guidance, 2 CFR Part 200. This is the regulation that governs federal grants administered by all federal agencies that applies to counties and other entities. Teh proposed ruling includes substantial changes to federal code.