January Newsletter

1/10/2025

Purpose:
Uniform Guidance (UG) is a government-wide framework for grants management that provides rules and requirements for federal awards. UG outlines the administrative requirements, cost principles, and audit requirements that all grant recipients must adhere to when managing federal funds.

The Federal Office of Management and Budget (OMB) revised the Uniform Guidance using plain language, in an attempt to make it easier to understand. One example, the use of “non-federal entity” was removed and replaced with “recipient or subrecipient” throughout the guidance, except for Subpart F: Audit Requirements.   

The purpose of the guidance is to highlight significant 2024 changes identified by the Department of Education and Workforce. Subrecipients should thoroughly review all requirements and revisions within the Federal Uniform Guidance and update their policies, procedures, and systems to ensure compliance.

Significant Updates:

200.113 Mandatory Disclosures
An applicant, recipient or subrecipient of a Federal Award must promptly disclose, in connection with a Federal Award, when it has “credible evidence” of violation of Federal Criminal Law involving fraud, conflict of interest, bribery or gratuity violations.  

 200.217 Whistleblower protection
Recipient and subrecipient must inform their employees in writing of whistleblower rights and protections.
200.1 Equipment
Capitalization threshold increases from $5,000 to $10,000. Equipment capitalization threshold is the lesser of the capitalization established by the recipient or subrecipient for financial statement purposes or $10,000 (200.1). Recipient or subrecipient who choose to increase the threshold amount must ensure the new threshold is appropriate.  

200.320 Procurement
Changed the term “small purchases” to “simplified acquisitions”.  Simplified acquisitions are procurement transactions that are more than the micro-purchase threshold of $50,000 (200.320(a)(1)(iv)) but does not exceed the simplified acquisitions threshold of $250,000. 
The UG revision also requires recipients and subrecipients to document and provide justification for all sealed bids rejected (200.320 (b)(1)(E)).  

200.303 Internal Controls
The UG revision added “document” to the Internal control requirement. Recipients and subrecipients must establish, document and maintain effective internal controls over federal awards (200.303 (a)). Previously UG only required a recipient and subrecipients to establish and maintain effective controls.  The requirement to “document” demonstrates or evidences the process and procedures management has created.  This helps with the identification of control points in the various processes.
In addition, recipients and subrecipients must take reasonable cybersecurity and other measures to safeguard information including protected personally identifiable information (PII) (200.303 (e)).

200.415 Required Certifications
The revision now requires subrecipients receiving a Federal award to certify to the pass-through entity (the Department) whenever applying for funds, requesting payment, and submitting financial reports. The following certification was added to the CCIP PCRs and FERs,

 “I certify to the best of my knowledge and belief that the information provided herein is true, complete, and accurate. I am aware that the provision of false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil, or administrative consequences including, but not limited to violations of U.S. Code Title 18, Sections 2, 1001, 1343 and Title 31, Sections 3729-3730 and 3801-3812.” Each such certification must be maintained pursuant to the requirements of § 200.334. This paragraph applies to all tiers of subrecipients.

200.501 Audit Requirements (Single Audit)

The single audit threshold increased from $750,000 to $1,000,000.   A non-Federal entity that expended $1,000,000 or more in the non-Federal entity’s fiscal year in Federal Awards must have a single audit. 

 Effective Date

The effective date of the revised Uniform Guidance provisions in 2 CFR Part 200 is October 1, 2024, except for the State-administered formula grants, which have an implementation date of July 1, 2024.   State-Administered formula grant include Title and IDEA grants. Additional Resources:

Auditor of State Bulletin 2024-006

Code of Federal Regulations