- The threshold for having a Single Audit has been raised from $750,000 to $1,000,000.
- Introduces the requirement that recipients and subrecipients take “reasonable” cybersecurity measures to safeguard information but does not establish a specific framework for cybersecurity requirements.
- Procurement removes the requirement to negotiate profit as a separate element of price for contracts where there is no price competition.
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Indirect Costs (Section 200.414)
- Increases the de minimis indirect cost rate from 10% to 15% of modified total direct costs.
- 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.
- Termination (Section 200.340)
- Clarifies that agencies may include an award term and condition that permits termination if an award no longer effectuates program goals or agency priorities.
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Mandatory Disclosures (Section 200.113)
- 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.
- 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.