The document provides a detailed overview of the proposed revisions to 2 CFR 200, commonly known as the Uniform Guidance, with a focus on the implications for research institutions and other stakeholders. These revisions, announced by the Office of Management and Budget (OMB) in October 2023, represent a substantial rewrite since the last major update in 2020. The changes aim to incorporate new statutory and administrative requirements, reduce unnecessary burden for agencies and recipients, clarify ambiguous sections, and improve the document’s language and organization. Key areas of revision span across acronyms and definitions, general and specific award requirements, cost principles, and audit protocols, with significant updates such as raising equipment and subaward thresholds, formalizing voluntary uncommitted cost sharing, adjusting indirect cost (F&A) rates, and refining audit requirements.
While many of the proposed changes are viewed positively—such as increased thresholds and clearer definitions—COGR (Council on Governmental Relations) notes several areas of concern that warrant close scrutiny and further comment, including the deletion of certain prior provisions, the clarity of definitions, and the need for alignment and consistency across the guidance. Additionally, unresolved issues from previous feedback, as well as novel suggestions for future improvement, are highlighted for ongoing advocacy. COGR is mobilizing cross-institutional workgroups to prepare formal comments and encourages community engagement ahead of the December 2023 comment deadline. The final rule is expected to be issued by early 2024, with an effective date tentatively set for later that year, pending OMB’s completion. The overall approach reflects an intent to support improvements while actively addressing lingering and emerging concerns within the academic research administration community.
