When the Office of Management and Budget (“OMB”) released the proposed rule to update the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (“Uniform Guidance”), the Federal Register Notice instructed that interested entities could submit comments until December 4, 2023. Feldesman Tucker Leifer Fidell LLP (FTLF) has reviewed the significant proposed changes and drafted comments for submission (available here). FTLF’s comments on proposed Uniform Guidance updates address a number of issues important to federal grantees, including equipment-related thresholds, de minimis indirect cost rates, mandatory disclosures under the False Claims Act, fixed amount awards and subawards, cybersecurity internal controls and other areas.

All federal grantees are welcome to review the comments and, if so inclined, submit their own using portions of FTLF’s comments on proposed Uniform Guidance updates as a model. All comments must be submitted before December 4, 2023 to www.regulations.gov.