Recipients and subrecipients of federal funding from the U.S. Department of Health and Human Services (HHS) and other federal agencies can soon expect greater uniformity in the rules that govern the administration and use of those funds.

HHS published an Interim Final Rule (the “Rule”) on October 2, 2024, adopting the Office of Management and Budget’s (OMB) codification of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the “Uniform Guidance”) at 2 CFR Part 200. HHS’s adoption of OMB’s version of the Uniform Guidance will go into effect on October 1, 2025, with a few exceptions. Until that time, HHS’s current version at 45 CFR Part 75 will remain, with a few adjustments to account for updates in the law and to add desired flexibility.

This article explains HHS’s phased approach to implementation of the rule and what updates add flexibility now. It also discusses how this move should ultimately alleviate some administrative burden and uncertainty for Community Action Agencies (CAAs), since they typically receive federal funds from multiple federal awarding agencies, including HHS, and will no longer need to comply with two versions of the Uniform Guidance.