Recalling Suggested Grant Terms that 'Missed the Cut'
After being engrossed in The Masters golf tournament last weekend, we still have golf, and its various terminology, on our minds. One particular saying refers to the players who didn’t score well enough after the first two rounds to continue being among the contenders vying for a payday in the final two rounds. It is said that these poorer-scoring players “missed the cut.” This phrase also works well for a whole host of definitions suggested by stakeholders that were rejected by the Office of Management and Budget (OMB) for inclusion in the subtitle A definitions (§200.1) within the 2024 revised uniform guidance (2 C.F.R. Part 200).
While OMB did include a handful of new terms within the definitions, there are numerous others that were suggested were not added. Terms that did not “make the cut,” according to the preamble to the final guidance, are as follows: advisory council, bad debt, beneficiary, conditional title, conference, construction, contingency provisions, conviction, cost of idle facilities, credible evidence, data management and sharing, depreciation, encumbrance, facilities, fraud, general support services, idle capacity, idle facilities, improper influence, initial equity contribution, key personnel, local partner, performance based payment, post-retirement health plan and strategic sourcing.
However, this may not be the end of the line for all of these terms. For example, OMB explained that many commenters suggested adding a definition of “encumbrance” in §200.1 instead of in §§200.311, 200.313 and 200.315 as included in OMB’s October 2023 proposed revisions to the guidance, while others noted deficiencies in the proposed definition within those sections. In response to these suggestions, OMB opted not to include a definition for this term in §200.1, noting that a single definition for encumbrance “may not fit equally well in all contexts under the uniform guidance in which it could be applied.” It further removed the term from the other three sections in subpart D in the final version.
OMB noted that for future updates to the uniform guidance, OMB would reconsider this term and provide a definition for it. “Removing the definition does not indicate that OMB now disagrees with its proposed definition, which may be reasonable to use in many contexts,” it said in the preamble to the final revised guidance. “OMB will continue to evaluate what definitions, if any, should be provided in future updates the uniform guidance.”
Thompson Grants will post an article Monday providing more information about the changes to the subpart A definitions at §200.1 in the final revised guidance, as well as key changes to subpart B (§§200.100-200.113). Make sure that you are aware of these definitions so that your own grant programs don't become noncompliant and “miss the cut.”
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
