Implementation and Readiness Guide for the OMB Guidance for Federal Financial Assistance

The “Implementation and Readiness Guide for the OMB Guidance for Federal Financial Assistance,” prepared by COGR, serves as a comprehensive resource for institutions preparing to comply with the revised Uniform Guidance (2 CFR part 200) effective October 1, 2024. The Guide presents key changes institution leaders must understand and implement, stemming from the 2024 revisions in federal requirements for grants and cooperative agreements. Major changes include increases in various financial thresholds (for equipment capitalization, single audit requirements, de minimis indirect cost rates, and Modified Total Direct Costs exclusions for subawards), as well as important alterations to the treatment of fixed amount awards, participant support costs, and the elimination of the Cost Accounting Standards Board DS-2 requirement for most higher education institutions. The revisions also introduce new or expanded mandates for areas such as mandatory disclosures (especially in cases of credible evidence of violations or conflicts of interest), cybersecurity requirements, tracking and reporting of equipment, and expanded anti-human trafficking compliance for overseas projects. The Guide urges institutions to review OMB’s full revisions and agency-specific implementation plans, as not all agencies may meet the compliance deadline; COGR continues to monitor and advocate for clarity on ambiguous or burdensome provisions, such as the treatment of unused leave and the removal of “fair share” cost principles. Appendices offer specific guidance on adjusting facilities and administrative cost rates, faculty communications, and ongoing tracking of agency adoption. The Guide highlights the need for institutions to align internal policies and system configurations with new federal standards, ensure robust internal controls, and communicate updates to stakeholders promptly. Throughout, the Guide balances anticipation of beneficial reforms—such as threshold increases and the elimination of certain reporting burdens—with caution about new administrative complexities and the potential for agency- or program-level variability in how rules will be interpreted and enforced. Institutions are encouraged to undertake readiness assessments, engage with cognizant federal agencies on indirect cost matters, and stay informed as further technical corrections and clarifications are expected.