Future Proposed Changes Establishing mechanisms to automatically adjust certain thresholds due to inflation or other triggering events (where permitted by law); Removing additional prior approval requirements; Challenges related to negotiating indirect costs, working with cognizant agencies or any other topics related to indirect costs that could be addressed in future updates; and Expanding the guidance in Subpart F to include more specific requirements on the scope of an audit (“proper perspective”) so that agencies have additional contextual information to guide them in resolving audit findings.
Proactively Address: Updating policies and procedures to align with the updated changes & thresholds (prior & current). Conduct a comprehensive review to identify specific changes that may impact grant management compliance requirements. Communicate changes to staff & subrecipients so that they are aware of the updates and address any questions concerning the revisions. Update training for staff, subrecipients, stakeholders and auditors to ensure they understand the implications of the UG revisions.
NEXT STEP Review all subawards to see what modifications will be required (DMR, MTDC, Prior Approvals, etc.) and documentation needed for modification; Review your grant awards to see how these changes may require a modification to your budget; Incorporate UG updates & requirements into your subrecipient boilerplate for future awards (Single Audit, etc.); Review subrecipient awarded policies and procedures to ensure they are in compliance with the updated UG;
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