As we approach President’s Day, it seemed like a perfect time to, once again, assess which federal agencies have finalized their adoption of the Office of Management and Budget’s (OMB’s) uniform grant guidance into their agency regulations, and more importantly, which ones have not.

In case you don’t remember, 28 federal agencies and offices issued a joint interim final rule in the Dec. 19, 2014, Federal Register implementing the uniform guidance. Because it was an interim final rule, the agencies continued to accept public comments on their implementation of the guidance, including specific agency additions and exceptions, before adopting them as final.

A few months ago, we determined that 12 agencies had adopted their regulations as final. List was the list as of early November, along with the date they announced their final rule in the Federal Register:

• Department of Education, Nov. 2, 2015;
• Environmental Protection Agency, Oct. 9, 2015;
• Department of Energy, Sept. 24, 2015;
• Office of National Drug Control Policy, Sept. 23, 2015;
• Institute of Museum and Library Services, Sept. 21, 2015;
• U.S. Agency for International Development, Sept. 17, 2015;
• National Aeronautics and Space Administration, Sept. 16, 2015;
• National Endowment for the Humanities, Sept. 16, 2015;
• National Archives and Records Administration, Aug. 25, 2015;
• Department of Veterans Affairs, July 22, 2015;
• National Endowment for the Arts, June 29, 2015; and
• Department of State, June 2, 2015.

Since then, the following agencies have adopted the regulations as final:

• Department of the Treasury, Jan. 27, 2016;
• Small Business Administration, Jan. 11, 2016;
• Gulf Coast Ecosystem Restoration Council, Dec. 9, 2015;
• Department of Housing and Urban Development, Dec. 7, 2015;
• Department of Veterans Affairs, Dec. 1, 2015;
• National Science Foundation, Nov. 27, 2015;
• Corporation for National and Community Service, Nov. 17, 2015; and
• Social Security Administration, Nov. 10, 2015.

By my count, that is only 20 agencies. We still have several that have yet to finalize their regulations, including such agencies as the Department of Agriculture, Department of Health and Human Services and Department of Commerce. However, even if an agency has not have completely adopted its regulations as final, the regulations implementing the uniform guidance are still effective for funding received by nonfederal agencies as of Dec. 26, 2014.

We will continue our watch on these agencies and provide another update as more agencies finalize their adoption of the guidance. Stay tuned!

Let us know your thoughts about the agency regulations adopting the uniform guidance. We’d love to hear from you.