The 2024 Uniform Guidance Revisions: OMB's Strategic Response to an Evolving Federal Landscape

Grant Regulations: A Historical Perspective

The Federal Grant and Cooperative Agreement Act of 1977 created momentum in the development of regulations pertaining to the award and administration of federal financial assistance by defining criteria for the use of contracts, grants, and cooperative agreements. In the same year, the Federal Program and Information Act was passed to provide for efficient and regular distribution of current information on Federal domestic assistance programs, now known as the Federal Assistance Listings. In 1978, OMB issued supplementary interpretive guidelines, further clarifying substantial involvement - the distinguishing characteristic between grants and cooperative agreements.

The Federal Managers Financial Integrity Act of 1982 required Federal agencies to establish internal accounting and administrative controls to prevent waste or misuse of funds and assure the accountability of assets. Legislation and regulations promoting accountability and transparency continue to flow thereafter.

In the 1980's, the government continued to assess and improve grants administration, focusing on the need for accurate, reliable, and relevant data. The Standards for Internal Control in the Federal Government and the Single Audit Act sought to improve stewardship by establishing critical data elements needed to inform funding decisions.

Accountability Architects: Designing a Risk-Based Solution

By the late 90's, there were over 600 Federal financial assistance programs. Administrative and program requirements. cost principles, and audit requirements applicable to federal awards could be found across multiple OMB circulars and codified across the vast universe that is the Code of Federal Regulations.

An audit or risk assessment of a grant program could encompass OMB Circular A-102 for state government, the pass-through entity; OMB Circular A-21 for costs incurred by the subrecipient, an institution of higher education; OMB Circular A-133 for audit requirements; and the Federal Acquisition Regulations for subawards to contractors. OMB and agency guidance, intended to acknowledge and meet the varying needs of each program, had its complexities. For some agencies and programs, the segmented compliance framework increased the administrative burden of designing an effective system of internal control over compliance with federal award requirements.

The Uniform Guidance, implemented in 2013, provided a governmentwide framework for grants management to strengthen program outcomes through innovative and effective use of grant-making models, performance metrics, and evaluation.

The Vista: Data-Informed Funding Decisions

Today, there are more than 2,000 Federal Assistance Listings, three times the number of programs catalogued in the 1990's. The 2024 Uniform Guidance revisions positions the Federal grants community to maximize the value and impact of federal financial assistance, paving the way for risk-based, data-driven processes that produce reliable financial and program information.

View the Guidance for Federal Financial Assistance - Final Rule on the Federal Register, here.