Key Dates

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Issued by

AGENCY FOR HEALTHCARE RESEARCH & QUALITY (AHRQ)

Purpose

Background

In April 2024, the Office of Management and Budget (OMB) issued revisions to the Uniform Administrative Requirements for Federal Financial Assistance, located at 2 CFR Part 200. On October 2, 2024, the Department of Health and Human Services (HHS)  issued an Interim Final Rule that provides the HHS implementation of the 2024 Revisions.

This Notice implements two primary changes HHS recently released, effective October 1, 2024, and describes AHRQ’s approach to implementing the Revisions.

1. As noted in the HHS press release, HHS announced an Interim Final Rule that was published in the Federal Register.  The Interim Final Rule implements revisions to the Uniform Administrative Requirements of 2 C.F.R. part 200 and outlines the HHS phased approach for adoption of 2 C.F.R. 200 in full.
2. HHS published a revised and updated HHS Grants Policy Statement (GPS).

The eight provisions are being implemented in 2 C.F.R. part 200 and are replacing the corresponding provisions in 45 C.F.R. part 75 as of October 1, 2024 (as shown below). HHS will adopt 2 C.F.R. part 200 in full, effective October 2025, with HHS specific modifications to appear in 2 C.F.R. part 300.

AHRQ Implementation of OMB/HHS Provisions

AHRQ has adopted the following administrative provisions effective for new, renewal, and continuation awards issued on or after October 1, 2024:

1. 2 CFR § 200.1 definition of *Modified Total Direct Cost (MTDC), which increases the exclusion threshold of subawards from $25,000 to $50,000 for modified total direct costs; definition of Equipment, which increases the threshold for determining equipment from $5,000 to $10,000; and definition of Supplies, which increases the threshold for determining supplies from $5,000 to $10,000. See COFFA guidance for details.
2. 2 CFR § 200.313(e), which increases the threshold for determining items that are considered to be equipment from $5,000 to $10,000 and clarifies that Indian tribes may use their own procedures for equipment disposition. See COFFA guidance for details.
3. 2 CFR § 200.314(a), which increases the threshold for determining supplies from $5,000 to $10,000.
4. 2 CFR § 200.320, which increases the micro-purchase threshold to $50,000.
5. 2 CFR § 200.333, which increases the amount of fixed amount subawards that a recipient may provide with agency prior written approval to $500,000.
6. 2 CFR § 200.344, which provides 120 days after the period of performance for submission of all final reports related to award closeout.
7. 2 CFR § 200.414(f), which adopts an increase in the indirect cost de minimis rate to 15 percent. See HHS Grants Policy Statement (GPS) for details.
8. 2 CFR § 200.501, which increases the single audit threshold to $1,000,000.

AHRQ Implementation of 2 CFR part 200 Provisions

* In accordance with guidance from the Council on Federal Financial Assistance (COFFA), AHRQ will continue to honor Negotiated Indirect Cost Rate Agreements (NICRA) negotiated prior to October 1, 2024. Cognizant agencies for indirect costs may—but are not required to—renegotiate existing NICRAs (i.e., issue revised or amended agreements) to reflect the new Modified Total Direct Cost (MTDC) base. OMB has encouraged cognizant agencies for indirect costs to accommodate requests to renegotiate existing NICRAs that are in effect beyond October 1, 2025. Institutions of Higher Education (IHEs) and non-profit research institutions should contact HHS Cost Allocation Services.

AHRQ will apply the eight provisions noted above and referenced in the Interim Final Rule to awards made on or after October 1, 2024, as well as to award modifications that add funding made on or after October 1, 2024. This includes supplements to awards and competing and non-competing continuations.

AHRQ will not apply the provisions to non-monetary actions to awards, such as amendments to lift restrictions, no-cost extensions, etc., and does not anticipate the need to issue a revised Notice of Award (NoA) to reflect the implementation of the provisions.

AHRQ’s Standard Terms and Conditions as noted in the most recent NoA remain applicable except where superseded by the changes. Effective October 1, 2024 any updates or references to the HHS Grants Policy Statement (GPS) in the NoA reflect the 2024 version of the HHS GPS. AHRQ will not apply changes retroactively.

AHRQ is not obligated to provide additional funds because of these changes and expects recipients to complete projects as originally peer reviewed and funded. Recipients may rebudget as allowable by the applicable policies and terms of award, if necessary, to reflect the provision changes, but as noted, AHRQ will not provide additional monies.

Inquiries

Please direct all inquiries to:

AHRQ Division of Grants Management 
Email: [email protected]