OMB Uniform Guidance Implementation “Top 10” Changes

OMB Uniform Guidance Implementation “Top 10” Changes

By now we are familiar with the OMB Uniform Guidance for federal awards, but how much do we know about its effect on non-profits and other non-federal organizations from a practical sense, and what should we be doing now to prepare for its implementation? What should we have already done? Background Recall that on December 26, 2013, the Office of Management and Budget (OMB) issued its Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance, or UG) that combined eight OMB Circulars into one comprehensive, uniform set of regulations. Federal agencies had until June 2014 to develop and submit to the OMB their own agency-specific plans for implementation of the UG. The UG, along with the federal agencies’ guidance, became effective for all new federal awards and incremental funding of existing awards after December 26, 2014, without much fanfare or excitement. What Now? Many organizations are struggling to find an easy way to determine how the UG will affect them and what changes their organizations need to make to comply with the UG. With detailed regulations from eight previous OMB Circulars combined into one body of regulations, this is no easy task. Because the UG applies to a broad spectrum of federal and non-federal entities with vastly varying operations and funding, it is difficult to compile a digestible, comprehensive summary of the changes that apply to all entities. Therefore, management will need to determine the areas that most affect their organizations and study those sections of the UG in detail. To help you identify those areas, we have compiled a “Top 10” list of the...