Portrait of Janet McDaid

by Janet McDaid

Partner at Han Group

The most extensive changes to the Uniform Guidance in ten years are slated for an effective date of October 1, 2024.  Here we share highlights of key changes of impact to nonprofit recipients of federal funding: 


  • Single Audit Requirement Threshold Raised
    • from $750,000 to $1,000,000 
  • De Minimis Indirect Cost Rate Raised
    • from 10% to 15% of modified direct costs 
  • Threshold Above which an Acquisition is considered Equipment Raised
    • from $5,000 to $10,000 
  • Subawards Recipients Amount to Apply to the Indirect Cost Rate Raised
    • from $25,000 to $50,000 
  • Maximum for Fixed Amount Awards and Sub Awards Raised
    • from $250,000 to $500,000 
  • Cybersecurity Internal Controls
    • Requirement for reasonable cybersecurity measures to safeguard information 
  • Added to Mandatory Disclosures
    • Promptly disclose credible evidence of the commission of a violation of the civil False Claims Act or Federal criminal law involving fraud, conflict of interest, bribery or gratuity violations under Title 18 of the United States Code


The revised guidance takes effect on October 1, 2024.  Federal agencies may elect to apply the final guidance to Federal awards issued prior to October 1, 2024, but if they do so, the effective date must be no earlier than 60 days after the Final Rule’s publication in the Federal Register.


For more information see the pre-publication version.  Note that this does not constitute the final guidance. The final regulation will appear on the Government Printing Office’s website and on Regulations.gov once recorded in the Federal Register.


This newsletter is to be used for informational purposes only and does not constitute legal, business, or tax advice. Each person should consult his or her own attorney, business advisor, or tax advisor with respect to matters referenced in this post. Han Group LLC assumes no liability for actions taken in reliance upon the information contained herein.

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