OMB Makes Technical Corrections to Uniform Guidance

January 6, 2015 | By Jerry Ashworth | Post a Comment

eraser-498474-mOops. Whoops. My mistake. Typo. Do-over. Got an eraser? Where’s the White-Out?

It doesn’t matter what you call it, some things in life are errors and need to be corrected. Some mistakes are bigger than others, but hopefully they can be corrected quickly and with as little annoyance as possible.

This brings us to the discussion of the technical corrections to the uniform guidance, which were included in the Dec. 19 interim final rule issued by the Office of Management and Budget and 28 federal agencies and offices that incorporated the uniform guidance into their regulations, effective Dec. 26, 2014. The technical corrections to the uniform guidance took up about 11 Federal Register pages and included amendments to all subparts in the guidance and the appendices.

One of the key changes that OMB and the Council on Financial Assistance Reform made in the technical corrections within Subpart A and the rest of the final implementation guidance was to remove references to the Dun and Bradstreet (D&B) Data Universal Numbering System (DUNS) and replace them with the term “unique entity identifier.” Therefore, it removed §200.32, Data Universal Numbering System (DUNS) number, and reserved the citation. This also affected the list of pass-through information required of subrecipients in §200.331.

Other corrections identified numerous provisions in the guidance where OMB meant to use the term “must,” which identifies a requirement, rather than “should,” which identifies a best practice. Still other corrections include references to Indian tribal governments and organizations that were not specified when the original guidance was released. Also, in Subpart D, post-award requirements, in the second sentence in §200.303(a) under internal controls, the uniform guidance inadvertently used the word “and” rather than “or” when discussing two internal control documents. The guidance now states that “internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government,’ issued by the Comptroller General of the United States or (not “and” as previous written) the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission.” It’s amazing how one word can make a big difference.

Thompson is writing a series of articles on these technical corrections. Subscribers to Thompson’s Grants Compliance Expert can follow a series of articles we are writing on these corrections. We are also updating the Federal Grants Management Handbook and Single Audit Information Service to reflect these corrections. Readers who had gotten familiar with the uniform guidance should be aware of the technical corrections to manage their future grants accordingly.

What technical correction to the uniform guidance was the most important to you? Let us know.



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