The Office of Management and Budget (OMB) has announced updates to the Uniform Guidance, 2 CFR 200, which took 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 Research Administration (OSRA) has been working thoroughly 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. OSRA will continue to monitor for agency updates and expects most updates to be incorporated directly into new awards.

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:

Highlighted 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.
• WCM’s FY25 IDC Rate Agreement has been finalized and includes the new threshold for all awards beginning 7/1/25 and beyond.
• All outgoing federal grant submissions should only utilize the equipment budget category for a single unit of equipment that is $10,000 or more. The Weill Research Gateway budget (WRG) will automatically exclude equipment costs from the MTDC when calculating the budget. Any single unit of equipment costing less than $10,000 must be included in the supplies category and is subject to the applicable IDC rate for the overall application.

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.
• WCM’s FY25 IDC Rate Agreement has been finalized and includes the increased threshold for all awards beginning 7/1/25 and beyond.
• All future outgoing federal grant submissions will collect IDC on the first $50,000 of each consortium, excluding Cornell University.  The Weill Research Gateway budget (WRG) will automatically collect IDC on the first $50K of each subaward, however, departments will need to manually adjust the MTDC for any outgoing subawards to Cornell University.

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.
• Effective Immediately, OSRA 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.

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.
• While these terms will likely continue to be used interchangeably for some time, OSRA will continue use of the term Indirect Costs in future policy updates.

Closeouts:

• Administrative closeout, publication, and data sharing costs are allowable costs after project period end date if liquidated prior to final financial report.
• Departments must coordinate with Grants and Contracts Accounting (GCA) for proper liquidations to ensure submission of financial report in accordance with funding agency requirements.

Prior approvals:

• Prior approval is required to move funding into participant support costs categories.
• Changes to personnel and contractors listed by name or position in the notice of award require prior approval (even if not key personnel in the project).
• Memberships, subscriptions, selling, marketing, taxes, entertainment and directly charging administrative and clerical salaries have been removed from the list of required agency approvals. However, agency-specific guidance for these costs must be observed.

Overview of Implementation Dates

Unless otherwise indicated these changes will be effective for:

• New awards issued on or after October 1, 2024
• Amended awarded issued on or after October 1, 2024, where the new guidance is explicitly incorporated.

Effective immediately, WCM budgets must account for the new equipment and subaward thresholds in all outgoing applications, as approved by the FY25 DHHS Rate Agreement. Adjustments to these thresholds will be made for collaborating institutions based on when they receive a new federally approved rate agreement.

Overview of changes in Weill Research Gateway Budgets

*Applicants must continue to manually exclude IDC on any outgoing funding to Cornell University or Cornell Tech.