OMB Proposes Revisions to Uniform Guidance

The Office of Management and Budget (OMB) posted proposed revisions for the uniform guidance into the Federal Register on October 5, 2023. A redline version of the proposed changes can be viewed here. Comments are due to the OMB by December 4, 2023.

Overview of Proposed Uniform Guidance

The proposed guidance includes clarification to the applicability of requirements and terminology and some relaxation and clarification to certain requirements that required prior approval from federal regulators. A few key proposed changes include the following:

  • Increase the audit threshold to $1 million from $750,000
  • Increase the de minimis indirect cost rate from 10% to 15%
  • Require the Schedule of Expenditures of Federal Awards (SEFA) to identify recipient of federal award for audits that cover multiple recipients

Although OMB is proposing a change to the audit threshold, as noted above, OMB isn’t proposing an increase to the threshold for type A and type B determination, related to major program determination.

Other proposed changes include additional requirements related to acts that directly support or advance trafficking in persons, additional requirements related to discrimination and changes to whistleblower protections.

Reviewing the proposed guidance and submitting any comments about the proposed changes by the December 4, 2023, deadline is recommended.

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If you have questions on how your organization could be affected by the proposed guidance, please contact your Moss Adams professional.

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