In response to the Office of Management and Budget’s (OMB) proposed updates to the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), attorneys at Feldesman Tucker Leifer Fidell LLP (FTLF) submitted nine pages of detailed comments.  

FTLF’s comments on the proposed Uniform Guidance changes supported and asked for additional clarification and revision on essential issues to federal grantees. Among the OMB’s proposed changes, the extensive comments identified areas such as:

• Equipment-related thresholds
• De minimis indirect cost rates
• Mandatory disclosures under the False Claims Act
• Fixed amount awards and subawards
• Cybersecurity internal controls 

Additionally, the firm’s attorneys noted a list of topics not addressed by the proposed Uniform Guidance changes that warrant attention, including:

• Leasehold improvements and federal interest
• Use of real property subject to a federal interest
• Volunteer time as a part of direct labor or the modified total direct cost allocation base
• Treatment of costs arising from mere “allegations” of violations of law as unallowable as areas missing from the proposed rule changes

More than 950 comments from various organizations, entities, and individuals were posted to the government’s submission website, www.regulations.gov. Submitted comments are public and can be browsed and reviewed here.

For more on FTLF’s Federal Grants Practice, please visit here.