Specific updates to Uniform Guidance
Proposed changes to uniform administrative requirements, cost principles, and audit requirements for federal awards are summarized below:
| Segment | Title | Number of sections | Proposed changes in sections | Percentage of section changes |
|---|---|---|---|---|
| Subpart A | Acronyms and definitions | 2 | 2 | 100% |
| Subpart B | General provisions | 14 | 4 | 29% |
| Subpart C | Pre-federal award requirements and content of federal awards | 17 | 8 | 47% |
| Subpart D | Post federal award requirements | 47 | 25 | 53% |
| Subpart E | Cost principles | 77 | 18 | 23% |
| Subpart F | Audit requirements | 22 | 6 | 27% |
| Appendix | Various | 12 | 6 | 50% |
| Total | 191 | 69 | 36% |
Subpart A – definitions (200.1)
Equipment* (200.313)
Threshold has increased from $5K to $10K for Indirect Cost rate (IDC) exemption.
Sub-awards* (200.333)
Threshold has increased from $25K to $50K for IDC exemption.
Intangible property
Expanded to include data, website, trade secrets, patent, intellectual property, software.
Participant support costs
Expanded to include anyone participating in or attending federally funded activities, but not responsible for implementation.
Prior approval (200.308)
Relaxed requirement.
Facilities and Administration (F&A) rates
All references to F&A should be replaced by IDC.
* Will not take effect immediate effect, pending NAU NICRA re-negotiation (2027)
Subpart B – General
Uniform Guidance review period (200.109)
Eliminated prescribed five-year review period; replaced with periodically.
Subpart C&D – Pre and post-award
Fixed amount (200.333, 200.400)
Increased threshold from $250K to $500K for subawards.
Entitlement to retain unexpended funds (not to be considered profit).
Cost Share (200.306)
Reaffirmed voluntary uncommitted cost share should not be reflected in any allocation of IDC.
Termination of award (200.340)
Removed language that allows a federal agency or pass-through entity to terminate an award if it “no longer effectuates program goals or priorities”.
Subpart E – Cost principles
(Agency) Prior approval (200.407)
No longer required for real property, equipment, admin staff costs, entertainment costs, memberships, subscriptions, participant support costs, selling/marketing costs, taxes.
IDC rates (200.414)
Re-affirmed pass-through entities must accept negotiated indirect cost recovery agreement (NICRA) for subs.
De Minimis IDC Rate (200.414)
Increased from 10% to 15% of modified total direct costs.
Data & evaluation (200.455)
Allowability for these costs now included
Closeout (200.472)
Allowability to recoup reasonable closeout costs until final financial report due date (~120 days after project end).
Admin & clerical staff (200.413)
Allowability of direct charging if they are integral to the award, can be specifically identified with award.
Conference costs (200.432)
Allowability of conference sponsor to provide dependent care for participants.
Subpart F – Audit
Single audit (200.501)
Increased threshold from $750K to $1M