1. The threshold for having a Single Audit has been raised from $750,000 to $1,000,000.
  2. Introduces the requirement that recipients and subrecipients take “reasonable” cybersecurity measures to safeguard information but does not establish a specific framework for cybersecurity requirements.
  3. Procurement removes the requirement to negotiate profit as a separate element of price for contracts where there is no price competition.
  4. Indirect Costs (Section 200.414)
    1. Increases the de minimis indirect cost rate from 10% to 15% of modified total direct costs.
    2. Relatedly, the Final Rule revises definition of modified total direct costs in section 200.1 to increase the value of each subaward that can be included in modified total direct costs from $25,000 to $50,000.
  5. Termination (Section 200.340)
    1. Clarifies that agencies may include an award term and condition that permits termination if an award no longer effectuates program goals or agency priorities.
  6. Mandatory Disclosures (Section 200.113)
    1. Applicants, recipients, and subrecipients must “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.
    2. The revised guidance changes certain provisions in 2 C.F.R. Part 25 related to obtaining unique entity identifiers (UEIs) and registering in the System for Award Management (SAM.gov), including clarifying that second-tier subrecipients and contractors under grants do not need to obtain a UEI and permitting agencies to exempt foreign organizations and foreign public entities from completing a full SAM.gov registration for Federal awards.