The Uniform Guidance, for people who write grant budgets.
What changed in the 2024 revision of 2 CFR 200, and how it shows up in your budget justification.
The 2024 revision at a glance
OMB published the revision in April 2024; it took effect for new federal awards on October 1, 2024. The thresholds below are the ones grant writers and finance staff touch most.
| Provision | Before | Now | Section |
|---|---|---|---|
| De minimis indirect rate | 10% of MTDC | Up to 15% of MTDC | 2 CFR 200.414(f) |
| Subawards counted in MTDC | First $25,000 | First $50,000 | 2 CFR 200.1 |
| Equipment threshold | $5,000 per unit | $10,000 per unit | 2 CFR 200.1, 200.313 |
| Single Audit threshold | $750,000 expended | $1,000,000 expended | 2 CFR 200.501 |
| Fixed amount subawards | Up to $250,000 | Up to $500,000 | 2 CFR 200.333 |
| Supplies residual inventory | $5,000 | $10,000 | 2 CFR 200.314 |
Five steps to a compliant budget
- [1]Confirm which version appliesThe 2024 revision applies to awards made on or after October 1, 2024, and to earlier awards only if the agency applies it by amendment.
- [2]Set your indirect cost approachUse your negotiated NICRA, or up to 15% of MTDC if you have no current negotiated rate. Check the NOFO for program caps.
- [3]Build MTDC correctlyExclude equipment, capital expenditures, patient care, rent, tuition remission, scholarships, participant support costs and subaward amounts over $50,000 each.
- [4]Test each costEvery cost must be allowable, allocable and reasonable under Subpart E, and consistently treated as direct or indirect.
- [5]Plan for auditIf you expect to expend $1,000,000 or more in federal awards in a fiscal year, plan for a Single Audit under Subpart F.
Costs that commonly draw questions
- Entertainment and alcohol (unallowable, 200.438 and 200.423)
- Lobbying and fundraising costs (200.450, 200.442)
- Personnel charges without time and effort support (200.430)
- Equipment purchased without required prior approval (200.439)
- Contingency line items without a clear basis (200.433)
Keep reading
- [+] The 2024 Uniform Guidance revisions: what grant writers must know
- [+] How to document indirect costs without a federal NICRA
- [+] Avoiding Single Audit findings in federal subrecipient awards
- [+] ELIXIR CONSUMERS Budget Narrative builder
This guide summarizes 2 CFR 200 and is not legal or accounting advice. Read the regulation at eCFR and follow your award terms.
Questions, answered
Can any organization use the 15% de minimis rate?
Recipients and subrecipients that do not have a current federally negotiated indirect cost rate may elect up to 15% of MTDC, without documentation. Programs with statutory caps on indirect costs still apply their caps.
Does the new Single Audit threshold apply to our current fiscal year?
The $1,000,000 threshold applies to fiscal years beginning on or after October 1, 2024.
Do I have to rebudget existing awards?
Not automatically. Awards made before October 1, 2024 follow their original terms unless the agency amends them to apply the revision.
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