Uniform Guidance Checklist: What Grant Recipients Need to Know

The 2024 revisions apply to federal awards issued on or after October 1, 2024.

Federal agencies had the option (but not the obligation) to apply the revised guidance to earlier awards, no sooner than June 21, 2024.

• Inventory all active federal awards and document which version of the Uniform Guidance applies to each one, based on award date and any agency elections or formal amendments.
• Create a reference guide so program, finance and procurement staff can easily identify the correct thresholds and requirements that apply to each award.
• Watch for award amendments, as they may change which version of the guidance applies.

Terminology has been updated throughout.

"Non-federal entity" has largely been replaced with "recipient" and "subrecipient." The guidance now names specific systems (SAM.gov, Grants.gov) rather than generic references. The Notice of Funding Opportunity (NOFO) template was completely overhauled to be shorter and clearer.

• Update internal policies, subaward templates and training materials to reflect current terminology (including assistance listing numbers and unique entity identifiers).
• Expect a different look and feel in funding announcements. Build time into your grant application process to adjust to the new NOFO format.

The 2024 revisions add explicit emphasis on documentation.

Recipients and subrecipients must establish, maintain and document internal controls over federal awards that provide reasonable assurance of compliance (§ 200.303).

• Review all federal awards and identify the compliance requirements applicable to each.
• Ensure internal controls over those requirements are in place and documented; verbal or informal processes will not hold up in a single audit.
• Continue aligning your control environment with the Committee of Sponsoring Organizations (COSO) Internal Control Integrated Framework or the GAO Green Book.

New requirement to take "reasonable cybersecurity and other measures" to safeguard information.

This includes protected personally identifiable information (PII) (§ 200.303(e)).

• Identify where award-related data and participant PII reside across your systems.
• Complete (or refresh) an assessment of your IT infrastructure and document the cybersecurity measures in place.
• Coordinate with IT to close gaps. "Reasonable" is undefined, so documented, risk-based judgment is your best defense.

Disclosure and whistleblower obligations are tightened.

Credible evidence of fraud, bribery or gratuity violations must now be disclosed "promptly" rather than "in a timely manner" (§ 200.113). Employees must be notified in writing of their whistleblower rights and protections (§ 200.217).

• Update your mandatory disclosure policy to reflect the "promptly" standard and define internally what prompt escalation looks like.
• Add written whistleblower notification to onboarding and annual compliance communications and retain evidence of delivery.

Pass-through entities (PTEs) must conduct risk assessments with updated criteria, focusing on financial stability, performance history and capacity.

PTEs must document corrective actions when deficiencies are identified, supporting accountability and improvement (§ 200.332).

• Adopt a standard risk-assessment template that incorporates the enhanced risk management requirements and complete it for every subrecipient before issuing a subaward.
• Document your results and tailor the depth of your monitoring to the assessed risk level.
• Issue management decisions on subrecipient audit findings within six months and verify timely corrective action.

PTEs may now conduct virtual site visits.

They may also conduct in-person visits as warranted and additional documentation standards emphasize detailed corrective action plans and timely follow-up on identified issues.

• Update site visit policies to incorporate virtual site visits.
• Ensure corrective action plans meet new documentation standards and that issues are followed up in a timely manner.

A new subrecipient certification requirement is in place.

Subrecipients must certify to the PTE when applying for funds, requesting payment and submitting reports (§ 200.415).

• PTEs: Build the certification language into subaward agreements, payment requests and reporting packages.
• Subrecipients: Confirm who is authorized to sign certifications and ensure they understand what they are attesting to.

The de minimis indirect cost rate increased from 10% to up to 15% of modified total direct costs (MTDC) for recipients and subrecipients without a federally negotiated rate (§200.414).

The rate applies to awards issued on or after October 1, 2024, and is not retroactive.

• Weigh the higher de minimis rate against negotiating a rate. The 15% rate narrows the gap for many organizations, but if your true indirect cost rate is meaningfully higher, negotiation may still pay for itself.
• Elect a rate up to 15% on new awards; you may charge less than 15% but choose deliberately and document the decision.
• Do not apply the 15% rate to awards issued before October 1, 2024, unless the award has been formally amended to allow it.

Federal agencies and PTEs must accept a federally negotiated indirect cost rate.

The 2024 revisions clarify that recipients and subrecipients may notify OMB of disputes with federal agencies over rate acceptance, though OMB will not act as a formal arbitrator.

• Know your right to full reimbursement of your fair share of costs and be assertive in applying your negotiated rate.
• If pressured to accept a reduced rate, request a written explanation, escalate through the agency and consider notifying OMB of the dispute.

The MTDC subaward exclusion threshold doubled from $25,000 to $50,000 (§200.1).

This means more of each subaward can carry indirect cost recovery.

• Update your MTDC calculations and budget templates so indirect costs are applied up to $50,000 of each subaward on covered awards.
• Confirm that your nonprofit accounting system applies the correct threshold by award, given the dual-compliance environment.

You must maintain the following:

• Written procurement policies
• A written conflict of interest policy

You must also use an authorized procurement method. Purchase thresholds have increased, but so has the expectation for documented price reasonableness, even on small purchases.

• Update your written procurement policies to reflect current micro-purchase and simplified acquisition thresholds. Document your organization's elections.
• For micro-purchases made without competitive quotes, retain documented support for price reasonableness (price history, catalog listings or market research).
• Reconfigure purchasing approval workflows in your financial systems to match the updated thresholds.

Veteran-owned businesses were added to the required "affirmative steps" for contracting outreach.

These businesses were added alongside small, minority-owned and women-owned businesses (§200.321).

• Update procurement policies and solicitation checklists to include outreach to veteran-owned businesses.
• Document affirmative steps taken in each formal procurement file.

Sustainable procurement is now encouraged with a preference for products that are reusable, refurbished, recycled or energy-efficient to the extent practicable.

Absolute bans on geographic preferences have been relaxed in favor of permissible scoring approaches.

• Incorporate sustainable procurement language into your purchasing policy.
• If local economic benefit matters to your mission, revisit whether a compliant geographic scoring mechanism belongs in your evaluation criteria.

Procurement thresholds were increased. The micro-purchase threshold increased from $10,000 to $50,000 and the simplified acquisition threshold increased from $250,000 to $350,000.

• Update procurement thresholds in your internal procurement policies

The equipment threshold doubled from $5,000 to $10,000 per unit (§200.313 and §200.1).

The threshold for remitting unused supplies at closeout likewise increased to $10,000 (§200.314).

• Decide whether to raise your internal capitalization threshold to match; if you keep a lower internal threshold (e.g., $5,000), configure systems to still track federally funded items between your threshold and $10,000.
• Update property management and closeout procedures to reflect the new supply remittance threshold.

The ceiling for fixed amount subawards increased to $500,000 (§200.333).

This increase gives PTEs more room to use outcome-based subaward structures.

• Evaluate whether fixed amount subawards fit programs where outcomes are clearly measurable; they can reduce administrative burden for both parties.
• Confirm prior written approval requirements with the federal agency before structuring a fixed amount subaward.

Continuing requirement: written payroll policies and records that reflect actual work performed.

In practice, auditors continue to see recurring issues: allocations based on budget only, after-the-fact reviews performed too infrequently and weak controls over the allocation process.

• Maintain a written payroll policy and confirm your federal payroll activity conforms to it.
• If you allocate payroll using budget estimates, build a recurring after-the-fact review into your close process and document the true-up.
• Test your own controls over payroll allocation before your auditor does.

The single audit threshold increased from $750,000 to $1,000,000 in annual federal expenditures (§200.501).

This increase is effective for fiscal years beginning on or after October 1, 2024 (fiscal year ends September 30, 2025, and later).

• Model your expected federal expenditures against the new threshold; some organizations will no longer require a single audit.
• If you fall below the threshold, confirm whether funders, lenders or state agencies still require an audit or other assurance before assuming the requirement disappears.
• Talk to your auditor early about which threshold applies to your fiscal year; timing matters in the transition period.

The Type A program threshold increased to $1,000,000 for entities expending between $1 million and $34 million in federal awards (§200.518).

This may reduce the number of major programs subject to audit.

• Revisit your major program expectations with your audit team; fewer major programs can mean a meaningfully lighter audit.

Questioned costs got clearer.

The definition was revised with examples, and when known questioned costs exist but the dollar amount can't be determined or reported, the audit finding must explain why (§200.516).

Report submission guidance also now recognizes that a cognizant or oversight agency may authorize extensions when the nine-month deadline would create undue burden (§ 200.512).

• Expect more precise dialogue with your auditor about questioned costs and be prepared to help quantify or explain them.
• Do not assume an extension; the nine-month (or 30-days-after-report) deadline remains the operating standard.