In 2024 the US Office of Management and Budget (OMB) issued a substantial revision to the Uniform Guidance — the government-wide rules at 2 CFR Part 200 that govern how federal grants and cooperative agreements are administered. Two changes drew particular attention in the research-administration community: the Single Audit threshold rose to $1 million, and the de-minimis indirect-cost rate rose to 15 percent. This article describes the revisions at a high level and is a neutral explainer, not accounting or compliance advice.
What the Uniform Guidance is
The Uniform Guidance consolidates federal requirements for cost principles, administrative requirements and audit into a single framework that applies across agencies. It governs questions such as which costs are allowable on an award, how indirect costs are recovered, what records recipients must keep, and when an organisation must undergo an audit of its federal spending. For context on how it fits the wider compliance landscape, see our overview of the Uniform Guidance.
Because the guidance is government-wide, a change to it ripples across every federal funding agency at once, which is why periodic OMB revisions matter so much to universities, hospitals, non-profits and other recipients.
The Single Audit threshold rises to $1 million
The Single Audit — sometimes called a Uniform Guidance audit — is the annual audit that a non-federal entity must obtain when it expends federal awards above a defined threshold in a year. The 2024 revision raised that threshold to $1 million in federal expenditure, up from the previous lower figure. Entities spending below the threshold in a given year are not required to obtain a Single Audit for that year, though they remain subject to records and monitoring expectations.
The practical effect is that some smaller recipients fall below the audit trigger, while larger research institutions — which routinely expend well above $1 million — continue to require a Single Audit. For the mechanics of the audit itself, see our explainer on the Single Audit.
The de-minimis indirect rate rises to 15 percent
Indirect costs (also called facilities and administrative, or F&A, costs) are real costs of supporting research — buildings, utilities, administration — that are not attributable to a single project. Organisations may negotiate an indirect-cost rate with the federal government, but those without a negotiated rate may instead elect a de-minimis rate applied to a defined cost base.
The 2024 revision raised the de-minimis rate to 15 percent, up from the long-standing 10 percent. This gives recipients that have not negotiated a rate — often smaller organisations and some subrecipients — a higher default recovery of indirect costs without the administrative burden of a rate negotiation.
- Who benefits: recipients and subrecipients without a current negotiated indirect-cost rate.
- How it applies: as a flat percentage on a defined modified-total-direct-cost base, per the guidance.
- What it does not change: organisations with negotiated rates continue to use those negotiated rates.
Other themes in the 2024 revision
Beyond the two headline numbers, the OMB revision aimed broadly at reducing administrative burden and improving clarity. Reported themes include plainer drafting, raised thresholds in several places to reduce low-value paperwork, and adjustments intended to make the rules easier to apply consistently. The detailed text governs in any specific case, and recipients generally read the revised 2 CFR Part 200 alongside their agency’s implementing guidance.
Effective dates and applicability
A practical question for any regulatory revision is when it applies. OMB’s revised guidance carried an effective date in 2024, and agencies implement the government-wide text through their own award terms. In general, the terms and conditions attached to a given federal award determine which version of the rules govern that award, so recipients commonly check the version referenced in their specific agreements rather than assuming the newest text applies retroactively to everything. New awards and new audit periods are the typical points at which the revised figures take practical effect.
This is why research-administration teams pay attention not only to the headline numbers but to the transition: an institution may have awards under both the prior and revised guidance running concurrently, and applying the correct version to each is part of careful grants management.
Why government-wide rules carry weight
It is worth underlining why a single OMB revision commands so much attention. Because the Uniform Guidance is government-wide, the same baseline rules apply whether an institution is funded by a health agency, a science agency, a defence research office or any other federal source. A change to the de-minimis rate or the audit threshold therefore propagates across an institution’s entire federal portfolio at once, rather than agency by agency. That breadth is what makes periodic OMB revisions a planning event for finance and research-administration offices, rather than a narrow technical adjustment affecting only one funding stream.
What research administrators should take away
For research-administration teams, the revisions translate into concrete operational questions: whether the higher Single Audit threshold changes an entity’s audit obligation in a given year; whether budgets and subaward terms should reflect the higher de-minimis indirect rate; whether financial systems and chart-of-accounts mappings correctly capture federal expenditures for the Single Audit determination; and whether internal policies, templates and training need updating to match the revised language. Many offices also revisit subrecipient risk assessments and monitoring procedures, since the rules governing pass-through entities are part of the same framework.
Subrecipient monitoring is one area where both changes intersect, because pass-through entities must apply the rules consistently to those they fund. The higher de-minimis rate in particular often appears in subaward budgeting discussions.
The two figures are easy to remember — a $1 million Single Audit threshold and a 15 percent de-minimis indirect rate — but the authoritative source is the revised regulation itself at whitehouse.gov/omb and the codified text in 2 CFR Part 200, which institutions consult for definitive application. For neutral background on related grants terminology, see our standards dictionary.