The "Implementation and Readiness Guide for the OMB Uniform Guidance," prepared by the Council on Governmental Relations (COGR), serves as a comprehensive resource for institutions to understand, prepare for, and implement the significant changes in the OMB's August 2020 revision to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200 and related parts). The guide not only summarizes numerous impactful updates, such as the extension of award closeout deadlines, new procurement and subrecipient monitoring thresholds, and increased transparency and accountability requirements, but also provides institutional assessments and points to consider for effective adaptation. Notable improvements include a 30-day extension to final reporting, safe harbor provisions for subrecipient audit reliance, and increased micro-purchase thresholds, all of which aim to reduce administrative burden and provide greater flexibility.
However, the guide also highlights several challenges and areas of concern, including the expansion of federal agencies' authority to terminate awards for reasons beyond poor performance, new statutory compliance requirements involving constitutional and national policy provisions, and ambiguities arising from inconsistencies between related regulations and agency guidance. Additionally, the replacement of CFDA numbers with "Assistance listing" terminology, evolving requirements for research security, and a shift toward performance-based program management require institutions to update internal systems and business practices accordingly. COGR recommends institutions remain vigilant for agency-specific implementations, stay current on evolving FAQs, and engage proactively to address uncertainties, particularly concerning audit, procurement, and subrecipient monitoring obligations. Overall, the guide underscores the need for thorough institutional review and adaptation to remain compliant while advocating for further clarifications and improvements from OMB.
