Sneak Preview: OMB Assessing Uniform Guidance Revisions Stemming from New Laws

December 8, 2017 | By Jerry Ashworth | Post a Comment

xgran_bookshot(The following was excerpted from a recent article in the Federal Grants Management Handbook.) The Office of Management and Budget (OMB) is evaluating how several federal laws will necessitate changes to the uniform grant guidance, an OMB grants official told attendees recently at the Maryland Governor’s Grants Office’s training conference.

Gil Tran of OMB’s Office of Federal Financial Management said that OMB plans to revise the uniform guidance to address provisions pertaining to federal grants within these laws, although he did not say when the changes would be forthcoming. Along with revisions stemming from these laws, the uniform guidance may experience further changes down the road. According to §200.109, Review date, “OMB will review [2 C.F.R. Part 200] at least every five years after Dec. 26, 2013.” Therefore, the first review would occur in December 2018.

One law enacted since the implementation of the uniform guidance is the National Defense Authorization Act (NDAA) for Fiscal Year 2017 (Pub. L. 114-328). Section 2339 of the NDAA increases the micro-purchase threshold for basic research programs and activities of the Department of Defense (DoD) science and technology reinvention laboratories.

The provision states: “For purposes of this section, the micro-purchase threshold for procurement activities administered under sections 6303 through 6305 of title 31 by institutions of higher education (as defined in section 101(a) of the Higher Education Act of 1965 (20 U.S.C. 1001(a)), or related or affiliated nonprofit entities, or by nonprofit research organizations or independent research institutes is —

“(A) $10,000; or

“(B) such higher threshold as determined appropriate by the head of the relevant executive agency and consistent with clean audit findings under chapter 75 of title 31, internal institutional risk assessment or state law.”

To comply with the NDAA threshold would require a change to the uniform guidance. The micro-purchase provision at §200.320(a) of the guidance can be used when the aggregate dollar amount for the purchase does not exceed $3,000 ($2,000 for acquisition for construction subject to the Davis-Bacon Act. Such purchases do not need to be advertised nor is there a requirement for obtaining quotations, if the nonfederal entity considers the price to be reasonable.

(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site.)


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