FASEB Comments on Proposed Changes to OMB Uniform Guidance

By: Yvette Seger
Wednesday, December 20, 2023
In October, the Office of Management and Budget (OMB) issued proposed revisions to several sections of its Guidance for Grants and Agreements to provide clarity and reduce administrative burden for both agencies and grant recipients.

Of particular interest to FASEB were proposed updates within 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. In its comments, FASEB reiterated its long-standing support to increase the threshold for determining items considered to be equipment (Subpart D, Section 200.313) from $5,000 to $10,000 and suggested a further increase to $25,000 to align with the base value of the National Institutes of Health Basic Instrumentation grant program (S10). In addition to raising the threshold, FASEB encouraged OMB to explore strategies to link such thresholds to real-time metrics of purchasing power and inflation, such as the Consumer Price Index.

Additional comments from FASEB supported researchers’ freedom to choose where to communicate and share their research findings, including preferred publication and reuse (Subpart D, Section 200.315—Intangible Property) and encouraged OMB to align terminology related to publication and printing costs with industry standard (Subpart E, Section 200.461—Publication and Printing Costs). Similar to its support for increasing the threshold for items deemed to be equipment, FASEB also supported the proposed increase in the threshold for single or program-specific audits from $750,000 to $1,000,000 per fiscal year as a strategy to reduce administrative burden.

OMB accepted comments on the proposed updates through December 4, 2023. All comments—including FASEB’s—can be accessed via regulations.gov. OMB plans to issue a summary of comments received in the preamble of the final guidance, the anticipated publication date for which is not specified.