Principal Investigators,
The Office of Management and Budget (OMB) has announced updates to the Uniform Guidance, 2 CFR 200, which will take effect on October 1, 2024. The Uniform Guidance is a set of federal regulations that govern the administration of federally funded financial assistance awards (i.e., grants and cooperative agreements). The revisions aim to streamline and enhance federal grant management and promote greater efficiency and accountability in the administration of federal funds. Key changes include updated cost principles, changes to prior approval requests, and enhanced audit requirements.
The Office of Sponsored Programs (OSP) has been working diligently to review the updated provisions and the impact of these changes on sponsored projects issued on or after October 1, 2024. The Federal Agencies are actively working on accompanying agency regulation, guidance, policies, and/or terms and conditions updates to reflect these changes; however, many agencies have not posted official updates as of today’s posting. OSP will continue to monitor for agency updates and expects for most updates to be incorporated directly into new awards. OSP’s Contracting Team will highlight changes to agency terms and conditions in the PI Acceptance process in Frevvo.
While most of the changes will not directly affect the day-to-day management of your sponsored projects, we do want to highlight a few of the changes:
Equipment and Supply Threshold Changes:
- 2 CFR 200.313: Equipment threshold increased from equaling or exceeding $5,000 to $10,000.
- 2 CFR 200.314: Supplies classified as an acquisition for less than $10,000.
- Boise State University will not be adopting this change at this time due to state equipment requirements.
Facilities and Administrative Costs/Indirect Costs Definition:
- OMB has removed the use of the term “Facilities and Administrative (F&A) cost” from the definition of Indirect Cost; however, Uniform Guidance and many federal agencies continue to use this term.
- OSP will be migrating our use of the term “F&A” to “Indirect Costs” to match the Uniform Guidance changes, including future updates to related Boise State University policies.
- In the meantime, these terms are likely to continue to be used interchangeably throughout the research and creative activity community at Boise State and throughout the federal government.
Modified Total Direct Cost (MTDC) Change:
- The definition of Modified Total Direct Cost (MTDC) is updated to allow indirect cost recovery for each subaward up to $50,000.
- This change is not applicable to recipient institutions until the definition is reflected in the institution’s Negotiated Indirect Cost Rate Agreement (NICRA).
- Boise State cannot implement the $50,000 threshold in budgeting until after our next NICRA is approved. Our NICRA will be eligible for negotiation in FY27.
De Minimis Rate for Indirect Costs for Subrecipients:
2 CFR 200.414 allows for the application of a 15% indirect cost rate for entities that do not have a Negotiated Indirect Cost Rate Agreement.
Beginning on October 1, 2024, OSP will approve subaward budgets in proposals with indirect costs for eligible entities at the 15% rate. This will not automatically apply to proposals that are submitted before October 1.
The full text of the Uniform Guidance revision is available in the Federal Register. If you have any questions about the upcoming changes, please contact OSP at osp@boisestate.edu or by calling 208-426-4420.