Sneak Preview: Definitions Added, Amended in Revised Subpart A
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) The Office of Management and Budget (OMB) is including several new definitions (§200.1) under the 2024 revisions to subpart A of the uniform guidance (2 C.F.R. Part 200), while also revising the mandatory disclosure provision (§200.113) in subpart B to support the use of “credible evidence.”
OMB announced final revisions to Title 2, including the uniform guidance, on April 4. The final guidance, which becomes effective for awards issued on or after Oct. 1 (unless federal agencies elect to implement it early), maintains many of the changes that OMB suggested in its October 2023 proposal to revise Title 2, while other proposed revisions have been amended in response to stakeholder comments.
Within the 2024 final guidance, OMB now generally uses the terms “recipient” and “subrecipient,” as appropriate, instead of the term “nonfederal entity” (although it still retains the use of “nonfederal entity” in several specific instances where the terminology applies, such as in subpart F). It adds that using the terms subrecipient or subrecipient provides clarity on the application of the Build America Buy America Act (Pub. L. 117-58) (see ¶446 in the Federal Grants Management Module) to federal awards made to for-profit organizations. In addition, OMB refers to “federal agencies” throughout the guidance, rather than “federal awarding agencies” as used in the existing guidance, and deletes the term “federal awarding agencies” from §200.1.
Among some of the changes in the final version compared to the 2023 proposed guidance, OMB amends the definition of “disallowed costs” to mean “charges to a federal award that the federal agency or pass-through entity determines to be unallowable in accordance with applicable federal statutes, regulations, the provisions of this part, or the terms and conditions of the federal award.” The term “expenditures” means “charges made by a recipient or subrecipient to a project or program for which a federal award is received.” A “federal agency” is defined as “an ‘agency’ as defined at 5 U.S.C. 551(1) and further clarified by 5 U.S.C. 552(f). The term generally refers to the agency that provides a federal award directly to a recipient unless the context indicates otherwise.”
(The full version of this story has now been made available to all for a limited time here.)
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