The Department of Health and Human Services ("HHS") has just released its long-overdue Grants Policy Statement ("GPS") revision, replacing the 2007 version. The Department released its new GPS almost a month after announcing that it will abandon its separate grant regulations in Part 75 and apply truly uniform federal grant administrative rules in 2 C.F.R. Part 200.
The new HHS GPS applies to awards and award modifications that add funding on or after October 1, 2024 for the 16 agencies that administer awards, including the Administration for Children and Families (ACF), the Centers for Disease Control and Prevention (CDC), Centers for Medicare & Medicaid Services (CMS), Food and Drug Administration (FDA), the Health Resources and Services Administration (HRSA), and the Substance Abuse and Mental Health Services Administration (SAMHSA). Consistent with historic practice, the HHS GPS does not apply to awards made by the National Institutes for Health (NIH), which have their own GPS.
Moreover, the new GPS adopts a simpler formatting style and supports HHS's transition from Part 75 to Part 200 through application of the increased thresholds for (i) subaward costs in calculating modified total direct costs, (ii) equipment, (iii) supplies, (iv) micro-purchases, (v) fixed-amount subawards, (vi) de minimis indirect cost rates, and (vii) audits, along with closeout 120 days extension.
The new GPS discusses, as expected, key items of interest such as construction and alteration/renovation, facilities and administrative costs, federal share and federal interest, for profit rules (including SBIR/STTR program concerns), research awards and cross-cutting national interest requirements. Time will tell if this revision hits the mark in helping to clarify murky regulatory areas or reducing administrative burden.
Make sure to attend our upcoming webinar events where we share Feldesman attorneys' views on this much expected HHS GPS overhaul.
- Tuesday, November 19 – Part 75: What's In, What's Out, and When Does It All Happen? Phase I
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