1. Organize
Organize Schedule of Expenditures of Federal Awards and indicate if each grant is subject to the 2024 revisions:
- Automatically subject to awards on or after 10/1/2024
- If revisions are desired for pre-existing awards, contact Agreement Officers to request award modifications to grant applicability
2. Review
Consult with your auditor to verify when the Subpart F Audit requirement revisions will be subject to your organization:
- Fiscal years beginning after 10/1/2024
3. Prepare
Information Technology and Cybersecurity:
- Contact funding agencies to understand changes to their pre-award risk evaluation process related to IT and Cybersecurity
- Perform a baseline assessment or benchmark against “Standards for Internal Control in the Federal Government” or COSO framework
- Review organization-wide budget to assess annual IT/Cybersecurity costs and develop a reasonable allocation methodology
4. Apply
Apply the new indirect rate of up to 15% (up from 10%) for de minimis:
- If electing de minimis, apply new rate of up to 15% (up from 10%)
- If electing NICRA, contact agencies that have historically required a lower rate to verify NICRA rate will be accepted
5. Update
Update federal compliance policies and procedures:
- Equipment
- Threshold increase from $5,000 to $10,000
- Updated disposition requirement, including supplies at “total” value
- Modified Total Direct Costs
- Subaward exclusion threshold increased from $25,000 to $50,000
- Conflict of Interest
- Include Board Members in policy
- Fixed Cost Subawards
- Ceiling increased from $250,000 to $500,000
- Procurement
- Updated terminology – change “small purchases” terminology to “simplified acquisitions”
- Include preferences for “veteran-owned businesses”
- Remove restrictions related to geographic preference requirements
- Financial Reporting
- If you historically used an agency-specific financial report format, contact agreement officers to transition to OMB-approved “government-wide” data elements only
- Subrecipient and Contractor Determinations
- Ensure policies include clear definitions of differences and determination
Contact
For help with implementation of the new OMB guidance, contact any member of our team.
