An Interim Final Rule on Grants a Week Before the Effective Date

December 19, 2014 | By Jerry Ashworth | Post a Comment

Federal registerThe Office of Management and Budget’s uniform grant guidance becomes effective next Friday, so the grants community has exactly one more week to become experts on all the provisions of the guidance. But why wait until the day after Christmas to get excited about the new guidance? OMB and 26 federal awarding agencies posted a joint interim final rule in today’s Federal Register that includes the agencies’ implementation of the guidance.

But be prepared, today’s notice is MASSIVE! Just the list of Code of Federal Regulations numbers at the beginning takes up several pages.

For those who are new to grants and haven’t been following what’s going on, OMB issued the uniform grant guidance, titled “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 C.F.R. 200)” on Dec. 26, 2013, and gave federal awarding agencies one year to implement the guidance into their regulations. The guidance is the biggest thing to happen to grants in years and includes numerous changes that affect the grants lifecycle from pre-award, to post-award, to audit and closeout. Today’s interim final rule includes the implementation regulations from the 26 federal agencies, and it goes into effect for new awards or funding increments on or after Dec. 26, 2014.

Many grant recipients have been particularly interested in how their specific federal awarding agency would adopt the guidance and whether the agency would seek any deviations or exceptions from the guidance. The Council on Financial Assistance Reform has included more information on the uniform guidance and today’s interim final rule, including a wrap-up of each agencies exceptions, which is available here.

The interim final rule also includes numerous technical corrections that OMB is making to the guidance in response to comments expressed from the grants community after releasing the guidance last year. OMB now plans to issue an amended version of 2 C.F.R. Part 200 after the guidance goes into effect on Dec. 26. The C.F.R. also will be revised to include agency changes to their regulations upon the Dec. 26 effective date.

Grants regulations for each agency adopting the uniform guidance will be included in Title 2 of the C.F.R. For example, for the Department of Health and Human Services, their regulations implementing the uniform grant guidance will now be found at 2 C.F.R. Part 300. Former grant guidance under the OMB circulars for HHS was contained in 45 C.F.R. Parts 74, 75 and 92.

If you’re looking for something to read over the weekend, or perhaps over Christmas week, OMB and COFAR have just what you need! Take the time to see how your agencies’ regulations may affect your grant programs. Also for more, check out this blog post from OMB Controller Dave Mader.

What is your reaction to the agency implementation on the guidance? Let us know what you think.

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