NEH Update on the 2024 Revisions to 2 CFR 200

(Published June 25, 2024)

Applicants to NEH for awards with expected issuance dates on or after October 1, 2024, should be aware of revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200) effective from that date. All NEH awards issued on or after October 1, 2024, will be subject to the revised regulations. You may incorporate these changes into your applications now.

Significant changes to 2 CFR Part 200 that may be most relevant for NEH’s applicants and recipients include:

  1. an increase in the de minimis indirect cost rate from 10% to 15% of Modified Total Direct Costs (2 CFR § 200.414 [f]),
  2. an increase in the threshold for determining equipment from a per unit cost of $5,000 to $10,000 (2 CFR § 200.313),
  3. an increase in the upper limit for computers as supplies from $5,000 to $10,000,
  4. an increase in the threshold for reporting unused supplies from an aggregate value of greater than $5,000 to $10,000 (2 CFR § 200.314),
  5. an increase in the threshold for excluding subaward costs from the modified total direct cost base from $25,000 to $50,000,
  6. a requirement that recipients verify that subrecipients are not suspended, debarred, or otherwise excluded from receiving Federal funds (2 CFR § 200.332), and
  7. an increase in the Single Audit Threshold from $750,000 to $1 million (2 CFR § 200.501).

Recipients of NEH awards issued prior to October 1, 2024, will not be subject to the new regulations, although supplements to these awards will.

NEH encourages applicants and recipients to read OMB’s final rule, now entitled OMB Guidance for Federal Financial Assistance, at: https://www.federalregister.gov/documents/2024/04/22/2024-07496/guidance-for-federal-financial-assistance.