Memo sent to RAC 10/2/2024

Dear Colleagues,

The implementation of revisions to the Uniform Guidance (2 CFR 200) became effective on October 1, 2024 (“Uniform Guidance 2024 Revisions”). These revisions include changes to limits and thresholds for equipment, subaward MTDC exclusions, de minimis rate, and single audit requirements; as well as simplifying language and updating terminology used. 

Implementation of changes to the equipment threshold and subaward MTDC exclusions by the University require a modified negotiated indirect cost rate agreement and, therefore, should not be included in budgets until that occurs. SPA and SPAC will provide guidance about implementation of those thresholds at the appropriate time.

Subrecipients without a negotiated indirect cost rate agreement may use the new 15% de minimis indirect cost rate. Budget and budget justification templates should be updated to use the term “Indirect Costs” instead of “Facilities & Administrative (F&A) costs.” Sponsors with budget templates will be incorporating this change on their own timelines. 

Uniform Guidance 2024 Revisions apply to new awards issued on or after October 1, 2024 and existing awards when the sponsor amends the award to add funding. Useful resources, including a 2 CFR Crosswalk and Federal Agency Implementation guidance, may be found here. In addition, I’ve attached the documents from the Uniform Guidance presentation last week at the UMB Research Administrator Day event.

In addition, the Department of Health and Human Services (HHS) is adopting the revised Uniform Guidance and will be repealing 45 CFR Part 75, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards.  More information can be found here:  https://public-inspection.federalregister.gov/2024-21984.pdf. HHS specific modifications to the Uniform Guidance will be found in 2 CFR Part 300. These changes have an effective date of October 1, 2024, for the eight provisions below, and an effective date of October 1, 2025, for the remainder of the provisions.

• Micro-purchase and simplified acquisition thresholds as required by Pub. L. No. 115-91, and OMB Memorandum 18-18; 2 CFR 200.320;  
• Closeout, 2 CFR 200.344. See 88 FR 63591 (Sept. 15, 2023)
• Subaward threshold for modified total direct cost calculation, 2 CFR 200.1 modified total direct cost; (Still $25,000 at UMB)
• Equipment threshold, 2 CFR 200.1, 2 CFR 200.313(e); (Still $5,000 at UMB)
• Supplies threshold, 2 CFR 200.1, 2 CFR 200.314(a);
• Fixed amount subaward threshold, 2 CFR 200.333;
• De minimis indirect cost rate, 2 CFR 200.414(f); and
• Audit threshold, 2 CFR 200.501.

Please continue to reach out to SPA for any questions you may have regarding the updates to the Uniform Guidance. 

Thank you,
Jill

Jill A. Frankenfield
Associate Vice President, Sponsored Programs Administration

Uniform Guidance - highlighted
Uniform Guidance Presentation Handouts 092424