The 2024 Uniform Guidance revisions: what grant writers must know

Why grant writers cannot leave this to finance

The Office of Management and Budget published the most significant revision of the Uniform Guidance in a decade in April 2024, effective for new federal awards made on or after October 1, 2024. Agencies were allowed to apply the changes earlier, and most have now adopted them in their own chapters of Title 2. Nearly two years later, we still see proposals built on the old numbers, usually because the budget template was copied from a 2023 application.

Writers need to know these changes because they show up in the budget justification, the indirect cost narrative, the subaward plan and the capacity section. A reviewer or grants management specialist who sees a 10 percent de minimis rate or a $5,000 equipment threshold in a 2026 budget will wonder what else is out of date.

The headline numbers

Four threshold changes matter most for applicants. Each one appears in budget forms or justifications, so update your templates before your next submission.

One caution: if your organization has a negotiated indirect cost rate agreement, the MTDC base and equipment definitions in that agreement still govern until the agreement is updated. Several universities and larger nonprofits have told their teams to keep using the old subaward base until their cognizant agency issues a revised rate agreement. Ask your finance office which base applies before you calculate indirect costs on a budget with subawards, and say which one you used in the justification.

• De minimis indirect cost rate: up to 15 percent of modified total direct costs, up from 10 percent (2 CFR 200.414(f))
• Subawards in MTDC: the first $50,000 of each subaward now counts toward MTDC, up from $25,000
• Equipment: the per-unit threshold rose from $5,000 to $10,000, so items below that are generally treated as supplies
• Single Audit: required when a non-federal entity expends $1,000,000 or more in federal awards in a fiscal year beginning on or after October 1, 2024, up from $750,000

Indirect costs: more flexibility, fewer arguments

The de minimis rate is available to any recipient or subrecipient that does not have a current federally negotiated indirect cost rate. The regulation now states plainly that the de minimis rate does not require documentation to justify its use and may be used indefinitely. An organization may elect a lower rate. Federal agencies and pass-through entities may not force a lower rate unless a statute or regulation requires it.

The rule for pass-through entities is also explicit: under 200.414(d), they must accept a subrecipient's federally negotiated indirect cost rate. If you are a subrecipient under a state agency or a university, you should no longer have to argue for your NICRA. If you are the pass-through, your subaward budgets need to reflect this, and your narrative should not promise partners a capped rate the regulation does not allow you to impose. Remember that some programs set their own limits by statute, so check the NOFO before applying any rate.

Subawards, fixed amounts and monitoring

Fixed amount subawards can now go up to $500,000 with prior approval from the federal agency, up from $250,000. That matters for coalitions where a lead applicant passes funds to smaller community partners that lack the accounting systems to manage cost-reimbursement subawards. A fixed amount structure tied to clear deliverables can be a better fit, but it still requires defined milestones and documentation that the work was done.

Subrecipient monitoring under 200.332 remains a frequent audit finding, and the revisions reorganized the required elements of a subaward. If your application describes a subaward plan, the capacity narrative should explain how you will assess each subrecipient's risk before award, what monitoring you will do, and how you will follow up on issues. Reviewers reading a multi-partner proposal increasingly look for this.

Closeout, cost sharing and plain language

Closeout timing changed. Under 200.344, recipients now have 120 calendar days after the end of the period of performance to submit final reports and liquidate obligations. Subrecipients have 90 calendar days, unless the pass-through entity sets an earlier date. Build those windows into your project timeline and your evaluation plan, since final outcome data often has to be compiled within them.

On cost sharing, 200.306 says voluntary committed cost sharing is not expected under federal research grants and may not be used as a merit review factor unless a statute or regulation allows it and the NOFO says so. Do not volunteer match you are not required to provide. Once you commit it, it becomes auditable. The revision also rewrote much of the text in plain language, using 'must' for requirements and 'should' for best practices, and restructured the required contents of a NOFO in Appendix I. That makes the regulation easier to cite accurately in your narrative.

What is changing next

The 2024 revision is not the end of the story. Executive Order 14332, issued in August 2025, directed OMB to revise the Uniform Guidance, including adding termination-for-convenience language to discretionary awards and limiting indirect costs. In May 2026, OMB published a proposed rule under docket OMB-2026-0034, with comments due in July 2026 and a targeted effective date of October 1, 2026. Check the Federal Register for the final text before assuming any proposed change applies to your award.

ELIXIR CONSUMERS' budget narrative builder carries the current thresholds and flags any template still using the pre-2024 figures. Whatever system you use, assign one person on the team to read each NOFO's indirect cost and cost sharing sections against the regulation, and to update the shared templates whenever OMB acts.