Government Affairs and Advocacy

The Office of Management and Budget (OMB) has released revisions to 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements along with other updated policies affecting U.S. Government grants and cooperative agreements. The new requirements were published in the Federal Register on August 13 (pp. 49506-49582) and take effect on November 12, 2020.

The regulations resulted from an extensive review and comment process that began in January. Humentum, with the support of numerous members, participated actively in that process. Despite being urged to do so, OMB chose not to open the entire Uniform Guidance policy document to comment. Instead, it requested input on selected sections of the regulation and on provisions intended to implement statutes enacted or presidential executive orders issued since 2 CFR 200 was originally made effective in December 2014. However, some clarifications related to OMB's previously issued Frequently Asked Questions (FAQ) have also been made. Still, there are extensive changes. In its announcement, OMB indicated that additional consultation with stakeholders will be pursued and that more changes could be forthcoming.

This webinar has been organized to (1) brief Humentum members on the published revisions; (2) identify policy areas which were called to OMB's attention during the comment period but which were not addressed; and (3) solicit member input concerning future steps to engage with OMB and federal awarding agencies on federal assistance management policy.

Among the topics that will be covered in the webinar are:

• Revised policies on indirect cost recovery by subrecipients.
• Expanded use of the de minimis indirect cost rate.
• Clarifications about periods of award performance, budget periods, and timing of costs.
• Steps to address and clarify the effect of non-authoritative policy guidance.
• Alignment of statutory dollar thresholds with approved procurement methods.
• Additional policies on domestic preference in procurements.
• Contracting with entities that use "covered technology" pursuant to Section 899 of the National Defense Authorization Act of 2019.
• Revision to close-out procedures for direct awards and subawards.
• Changes to criteria for award terminations.
• Important definitional changes cutting across 2 CFR 200 and other Title 2 assistance regulations.
• A new regulation implementing the "Never Contract with the Enemy Act".
• "Untouched issues" that remain important to NGO's.