The Office of Management and Budget (OMB) made significant updates to Title 2 of the Code of Federal Regulations (CFR) 200, which establishes administrative requirements, cost principles, and audit requirements for all Federal financial assistance. The updates, known as the Uniform Grants Guidance 2024 Revisions (2024 Revisions), apply to projects that start on or after October 1, 2024.
EAC Implementation
The 2024 Revisions to the Uniform Guidance are intended to reduce the administrative burden on federal agencies and recipients and improve the clarity and consistency of language and federal policies.
The EAC has officially adopted the 2024 Revisions, and all HAVA awards issued after October 1, 2024, are subject to the revised guidance, including Election Security funds. 101 and 251 grants will also adopt the 2024 Revisions through an amendment, allowing states to use the same set of rules and requirements for all their open awards. The timeline for program transition is as follows:
Election Security: Awards were amended with FY25 supplemental funding. Grantees who do not accept the funding will be given the opportunity to amend their existing Election Security award.
251 Requirements Payment and 101 Election Improvement: Grantees were notified in June 2025 of the opportunity to adopt the 2024 Revisions.
Effective Dates: The 2024 Revisions will be effective as of the amended date on the Notice of Award (NOA). The following exceptions may be implemented retroactively to the beginning of the award period, provided they do not add any additional burden to grantees:
- 2 CFR § 200.313 Equipment: Increases the equipment threshold from $5,000 to $10,000, allows federal agencies to determine whether disposition requirements are necessary, and affords Indian Tribes the ability to follow their own disposition procedures.
- 2 CFR § 200.314 Supplies: Increases the unused supply threshold from $5,000 to $10,000 and clarifies that the requirements for unused supplies apply to the aggregate value of all supply types.
- Single Audit and major program threshold increased to $1,000,000 effective for non-Federal entity fiscal years beginning on or after October 1, 2024. These changes are effective regardless of whether the EAC takes any action to amend existing awards based on OMB’s statutory authority to adjust the dollar amount of threshold at 31 U.S.C. 7502.
HAVA grantees should work with their Grant Specialists to understand when and if their current projects are affected.
Resources:
2 CFR 200
Implementation Memorandum
Key Changes
Redline Edits
Council for Federal Financial Assistance (COFFA) website