The OMB provided notice of Request for Information (RFI) and notification of proposed guidance to 2 CFR. The OMB, through the RFI and the proposed rule revisions, is seeking to harmonize the regulations of federal grants and agreements to improve efficiencies, allow for greater transparency, and create a more effective process for both grant recipients and federal agencies. Feedback on the guidance and revisions to 2 CFR are due on or before March 13, 2023.
OMB has issued an updated memo addressing Covid-related flexibilities provided under prior OMB Memos. Many of the flexibilities offered in the earlier memos have been rescinded. The memo does permit two flexibility measures to continue – coverage of salaries and single audit submission deadlines. However, the flexibility for 2020 year ends has been rescinded.
This week found our regulatory agencies working hard to address COVID-19. OMB expanded its administrative relief to entities impacted operationally by current conditions. The AICPA provided guidance on how to audit inventory when you can’t be on site. The SEC provided disclosure guidance to address COVID. GASB has indicated potential delays of two major standards in response to operational issues. FASB has worked with the federal agencies to address loan modifications and TDRs in light of banks helping customers dealing with COVID fallout. Standard setting may be on hold while they all take the time to address the current situation.
OMB has issued administrative relief for those who receive federal financial assistance that is DIRECTLY RELATED to COVID-19. The GAQC has provided clarifying guidance on who the relief is directed to. We expect additional guidance for a broader subset of nonfederal entities due to operational issues in the near future. Universities are also impacted significantly by COVID-19 due to instructional disruption. The Department of ED has also provided guidance on the impact on student financial assistance. This blog reviews the major impacts of this OMB alert.
The Office of Management and Budget (OMB) has proposed changes to the Uniform Guidance (2 CFR, Part 200). The proposal takes into consideration the President’s Management Agenda, alignment with statutory requirements and clarifications. OMB is required to update the Uniform Guidance every five years. Comments are due by March 23, 2020 and must be submitted electronically to www.regulations.gov.