Revised Uniform Guidance Becomes Effective Today

Jerry Ashworth
November 12, 2020 at 07:56:35 ET
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Today’s the day! It’s been a long time coming but today is the day that all the revisions to the Office of Management and Budget’s uniform guidance (2 C.F.R. Part 200) issued on Aug. 13 become effective. So what does that mean? Awards issued from today forward, or modifications to existing awards, must follow the provisions in the revised guidance. However, if you have an existing federal award prior to today, you would still comply with the provisions of the traditional uniform guidance.

Hopefully, applicants for and recipients of grants and cooperative agreements have reviewed the changes to the uniform guidance to determine how to plan for them and how to best update their internal policies and procedures. Because many of the citations have changed in the revised guidance due to the addition of new provisions, your current policies for awards going forward may now be out-of-date and would require adjustments.

In addition, we recommend that entities applying for awards that they have sought in the past to thoroughly read the notice of funding opportunity to determine if there are any changes compared to previous years. Along those lines, once receiving an award, it will be critical that they understand the terms and conditions of the award to ensure that they maintain compliance with applicable requirements.

And as we have explained in previous articles, make sure you know which version of the guidance applies to your award. For example, while the closeout provision in the revised guidance allows recipients 120 days to submit closeout documentation, recipients who have existing awards dated prior to today must still follow the traditional uniform guidance, which requires that these documents be submitted within 90 days.

Thompson Grants has now posted the complete version of the revised uniform guidance here. We also will maintain the traditional uniform guidance on the Grants Compliance Expert site for older awards. Further, we are making available a print version of the revised guidance — 2 CFR 200 Uniform Guidance: 2020 Revisions Edition for $49, which can be purchased here. For a rundown of all the resources Thompson Grants is making available related to the revised guidance, check out our 2020 Uniform Guidance Changes Info Center.

These are definitely exciting times in the grants world! We look forward to this new era in grants administration!