Federal Financial Assistance (Uniform Guidance) Center

Organize Schedule of Expenditures of Federal Awards and indicate if each grant is subject to the 2024 revisions:

• Automatically subject to awards on or after 10/1/2024
• If revisions are desired for pre-existing awards, contact Agreement Officers to request award modifications to grant applicability

Consult with your auditor to verify when the Subpart F Audit requirement revisions will be subject to your organization:

• Fiscal years beginning after 10/1/2024

Information Technology and Cybersecurity:

• Contact funding agencies to understand changes to their pre-award risk evaluation process related to IT and Cybersecurity
• Perform a baseline assessment or benchmark against “Standards for Internal Control in the Federal Government” or COSO framework
• Review organization-wide budget to assess annual IT/Cybersecurity costs and develop a reasonable allocation methodology

Apply the new indirect rate of up to 15% (up from 10%) for de minimis:

• If electing de minimis, apply new rate of up to 15% (up from 10%)
• If electing NICRA, contact agencies that have historically required a lower rate to verify NICRA rate will be accepted

Update federal compliance policies and procedures:

• Equipment
  • Threshold increase from $5,000 to $10,000
  • Updated disposition requirement, including supplies at “total” value
• Modified Total Direct Costs
  • Subaward exclusion threshold increased from $25,000 to $50,000
• Conflict of Interest
  • Include Board Members in policy
• Fixed Cost Subawards
  • Ceiling increased from $250,000 to $500,000
• Procurement
  • Updated terminology – change “small purchases” terminology to “simplified acquisitions”
  • Include preferences for “veteran-owned businesses”
  • Remove restrictions related to geographic preference requirements
• Financial Reporting
  • If you historically used an agency-specific financial report format, contact agreement officers to transition to OMB-approved “government-wide” data elements only
• Subrecipient and Contractor Determinations
  • Ensure policies include clear definitions of differences and determination