The Office of Management and Budget (OMB) Guidance for Federal Financial Assistance – Final Rule went into effect on October 1, 2024. Key revisions include increases to thresholds for equipment / supplies, subaward amounts included in modified total direct costs (MTDC), de minimis indirect cost rates, fixed amount awards and Single Audits. Increases for equipment thresholds from $5,000 to $10,000 and a revision to include up to the first $50,000 (previously $25,000) of each subaward in MTDC can only be implemented upon approval of the University of Hawai‘i’s (UH’s) Negotiated Indirect Cost Rate Agreement (NICRA). An indirect cost rate proposal was submitted in fiscal year (FY) 2024 to our cognizant agency, however negotiations have not yet been initiated. The negotiation period generally lasts about a year so at the earliest, we do not anticipate any changes to the equipment and subaward thresholds until FY2027 (beginning July 1, 2026). As negotiations begin, we will keep you posted on the anticipated dates for implementation. Aside from the two (2) threshold increases noted above, all other revisions are effective for Federal awards issued on or after October 1, 2024. As each Federal agency will be implementing specific guidelines, please refer to the terms and conditions referenced in your awards.
A summary of key changes with UH’s implementation plans is attached. Policies and procedures, as well as other system requirements, are being modified to comply with these changes. A new policy for Participant Costs is also being drafted. In addition, the Council of Governmental Relations (COGR) has published an Implementation and Readiness Guide to help institutions prepare for and implement OMB’s revisions.
Additional information will be shared as we continue with the implementation of these Uniform Guidance Updates.
Please send any questions or comments to orscomp@hawaii.edu.