With the October 1, 2024 deadline for implementation of OMB's Uniform Guidance revisions fast approaching, today the Department of Health and Human Services ("HHS") dropped big news by announcing that HHS is abandoning its separate Part 75 codification that dates to 2014 and, effective October 1, 2025, will align instead with other federal agencies in adopting 2 C.F.R. Part 200 with minor amendments in 2 C.F.R. Part 300.
However, the pre-publication Interim Final Rule (IRF) draft HHS released today explains that it will not delay implementation of important Uniform Guidance changes. Effective for awards issued on or after October 1, 2024, HHS will apply, along with most other federal agencies, the increased thresholds in Part 200 that are applicable to (i) subaward costs in calculating modified total direct costs, (ii) equipment, (iii) supplies, (iv) fixed-amount subawards, (v) de minimis indirect cost rate, and (vi) audits.
As the largest federal grant-making agency and federally-designated Quality Service Management Organization ("QSMO") for grants management, HHS's adoption of Part 200 is a notable and positive step in grants administration, resolving the most obvious "non-uniform" part of the original issuance of the Uniform Guidance at the end of 2014.
HHS will receive comments on the proposed IFR no later than 30 days from its publication in the Federal Register.
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