On January 22, 2020, the federal Office of Management and Budget (OMB) announced proposed revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), 2 C.F.R. Part 200, that would affect all federal grant recipients, including Community Action Agencies (CAAs). If implemented, the proposed revisions would make several key changes to the Uniform Guidance, including:
- Giving more organizations the option of adopting the 10% de minimus rate for indirect cost recovery;
- Allowing organizations to request higher micropurchase thresholds for procurement beyond the current $10,000 limit;
- Clarifying the requirement that pass-through entities must recognize and pay a subrecipient’s indirect costs, and specifying options for doing so;
- Revising definitions in an attempt to further standardize the grants management business process and data; and
- Shifting the balance between compliance and performance to provide federal agencies with the opportunity to streamline burdensome compliance requirements for programs that demonstrate results.
Presented on: February 20, 2020
Presented by: Caroline F. Kelley, Esq., Veronica Zhang, Esq. and Allison Ma’luf, Esq., CAPLAW
