In December 2014, the U.S. Office of Management and Budget (OMB) implemented the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Commonly referred to as the “Uniform Guidance,” the authoritative set of rules and regulations governing the administration and operation of federal awards superseded earlier guidance that was in the form of OMB circulars.
The publication of the Uniform Guidance was a major undertaking that streamlined administrative requirements while also safeguarding against the misuse of federal funds. Since its implementation in 2014, the Uniform Guidance, also referred to as Single Audit, had largely remained unchanged with only minor updates or revisions. At the start of 2023, the OMB aimed to make significant updates to the Uniform Guidance to clarify or relax certain terms and requirements.
The revisions to the Uniform Guidance were published in a red-line, pre-publication version on October 5, 2023, with a 60-day public comment window. After consideration of public comment, the OMB released the revised Uniform Guidance with major content changes on April 4, 2024, which becomes effective for awards made on or after October 1, 2024.
Some of the most notable changes in the revised Uniform Guidance are as follows:
- The guidance increased the single audit threshold to $1 million, from the previous threshold of $750,000.
- The guidance updated the per-unit acquisition cost threshold to $10,000, from $5,000, for determining an item is “equipment,” and to clarify that agencies may permit the non-federal entity to retain equipment with no further obligation to the federal government when the act is not prohibited by federal statue or regulation. Previously all equipment or proceeds from the sale of equipment purchased with federal grant funds were to be remitted back to the awarding agency unless otherwise specified.
- By increasing the equipment threshold to $10,000, all tangible personal property less than the equipment threshold is now considered supplies. OMB also clarified the disposition requirements for unused supplies apply to the aggregate value of all supply types.
- Sealed bids received from requests for proposals by local and tribal governments are no longer required to be unsealed in a public forum. This change reduces the burden of scheduling a special public meeting or waiting until an already scheduled meeting occurs to open sealed bids.
- The guidance revised the section on program income to provide clarifications regarding the use and expenditure of program income. Program income is allowed for certain closeout costs under this revision. Clarification was also provided for each of the three methods for the use of program income.
- The OMB increased the de minimis indirect cost rate to 15%, from 10%.
Additional changes can be found in the Federal Register. PYA is committed to assisting grant recipients with the latest changes to the Uniform Guidance. Contact our executives for assistance.