What it Means for Federal Agencies and How to Comply Before Implementation Date
For the first time in more than 10 years, the U.S. Office of Management and Budget (OMB) released a long-awaited update to its Uniform Guidance, Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. The intent of these updates, is to help grant recipients “focus more on the people they serve and to deliver results for their communities.”
Imbedded in Title 2 of the Code of Federal Regulations, the new release, among other things, clarifies what grant recipients can and can’t spend money on.
“The costs related to data and evaluation,” the final guidance makes clear, “are allowable.” And the new guidance expands on this important concept:
Data costs include (but are not limited to) the expenditures needed to gather, store, track, manage, analyze, disaggregate, secure, share, publish, or otherwise use data to administer or improve the program, such as data systems, personnel, data dashboards, cybersecurity, and related items. Data costs may also include direct or indirect costs associated with building integrated data systems—data systems that link individual-level data from multiple State and local government agencies for purposes of management, research, and evaluation.
Federal agencies have until May 15, 2024 to tell OMB their plans for implementing the 2024 revisions, which apply to all federal awards issued on or after October 1, 2024.
The release of the final guidance was accompanied by an OMB memorandum well as reference guides related to evaluation, data, community engagement, notice of funding opportunities, labor and burden reduction.
The OMB memo refers to the Federal Program Inventory, which relies on “assistance listings” as the comprehensive source of federal financial assistance program information. Agencies have until June 1, 2024 to identify the assistance listings associated with each of their grant programs so OMB can use it in updating the program inventory.
OMB’s memo also focuses on Notice of Funding Opportunities (NOFOs), or grant announcements. Agencies are required to have a plan for increasing the accessibility, readability, clarity and design of their NOFOs for new discretionary assistance programs that are awarded competitively.
There are several additional reforms achieved by the updated guidance and accompanying memo and reference guides. Grant recipients and those involved in the grant making and administration process are advised to study the contents closely.
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