2024 Uniform Guidance Publish Date Is Among Many Important Ones

In Walt Disney’s Alice in Wonderland, some may remember the March Hare frantically uttering “I’m late! I’m late! For a very important date!” In the grants world, we could make that plural (i.e., “dates”), and we hope that federal agencies aren’t late in meeting some of these dates.

The first important date is today, April 22, as the final guidance for the revisions to Title 2 of the Code of Federal Regulations, including the uniform guidance (2 C.F.R. Part 200), has officially been published in the Federal Register. Combining certain dates in this document, along with those in the Office of Management and Budget’s (OMB) Memorandum M-24-11, released on April 4, there are several dates of great importance that could be of interest to all grants stakeholders.

Let’s try to run down some of these dates in order:

• April 22 — The 2024 revisions to the uniform guidance are published.
• May 15 — All federal agencies must submit to OMB their plan for implementing the 2024 revisions.
• June 1 — Federal agencies must identify the Assistance Listings associated with each program or activity reported under the Payment Integrity Information Act of 2019, and submit to OMB a crosswalk of Assistance Listings and program or activity names used for inclusion in the Federal Program Inventory.
• June 21 — The earliest date by which federal agencies may elect to implement provisions in the 2024 revisions to Title 2 within grant notices of funding opportunities and award terms and conditions.
• Aug. 1 — Federal agencies must submit a notice of funding opportunity simplification plan to OMB.
• Oct. 1 — The effective date for the 2024 revisions to the Title 2.
• Nov. 15 — Federal agencies must complete an initial assessment of their current Assistance Listings and their preliminary plan to work toward establishing a single Assistance Listing, where appropriate, for each program.

If you are a grant manager at a federal government, it’s time to take out your calendars and circle these very important dates. Grant recipients and applicants should also be aware of these dates to better understand what is going on in the overall federal grants environment.

And with all the excitement over the release of the 2024 revisions, let’s not forget that these aren’t the last ever revisions. A provision in the 2024 guidance at §200.109 now notes that the guidance will be reviewed “periodically,” so more changes could eventually come in the future. To offer a second Walt Disney reference, when discussing the various Disney theme parks, he quipped that they were “always in a state of becoming.” After 10 years now, and seeing all the changes to the original uniform guidance, we can probably say the same thing about 2 C.F.R. Part 200.

Join us for our following Thompson Grants events:
Thompson Grants Workshop: Procurement | May 23, 2024 | Virtual Event
Federal Grants Forum | June 26-27, 2024 | Columbus, Ohio