The document provides a comprehensive review of the latest Office of Management and Budget (OMB) Guidance for Federal Financial Assistance, focusing particularly on the revisions released in April 2024 and their implications for institutions engaged in federally funded research and financial assistance. The presentation, led by experts from several prominent universities and the Council on Governmental Relations (COGR), traces the historical development of the guidance, outlines the timeline and anticipated steps leading up to the October 1, 2024 implementation date, and examines key changes from an institutional perspective. Notable revisions include increases in certain financial thresholds and cost-sharing policies, updated rules for indirect costs and equipment capitalization, enhanced requirements for mandatory disclosures, and modifications to the management of fixed amount awards and subawards. The guidance aims to enhance clarity and consistency, but also introduces new compliance demands and ambiguities requiring further clarification and adjustment by recipient organizations.
Panelists highlighted critical considerations such as transitioning to new equipment capitalization thresholds, adapting institutional policies and accounting systems, managing administrative closeout costs, and understanding the altered expectations for cost sharing and pass-through entity responsibilities. Institutions must now navigate revised reporting requirements, anticipate the impact of “future” items identified by OMB, and prepare for increased scrutiny in certain areas, such as the allowability of costs and auditing of fixed amount awards. The document underscores the importance of ongoing institutional review—via interdepartmental workgroups or primary office leadership—robust advocacy, and the need for additional guidance, particularly in the form of updated FAQs, to ensure smooth and compliant adaptation to the evolving federal regulatory landscape. Overall, the revised OMB guidance presents both opportunities for streamlined oversight and challenges that require coordinated institutional response and sustained stakeholder engagement.
