Interactive reference · 2 CFR Part 200 (89 FR 30046)

Pre-2024 vs. 2024
Uniform Guidance side by side.

Filter by category or search by section number to compare legacy thresholds against the 2024 Uniform Guidance revisions, check the qualifying conditions, and jump straight to the eCFR text.

Showing 12 of 12 verified 2024 Uniform Guidance provisions.

Thresholds & MTDC · 2 CFR 200.1 & 200.313

Read 2 CFR 200.1 & 200.313 on eCFR ↗

Equipment capitalization threshold

Pre-2024 Uniform Guidance

Lesser of the institution's capitalization threshold for financial statement purposes, or $5,000 per unit (useful life > 1 year).

2024 Revised Rule (Oct 1, 2024)

Lesser of the recipient's or subrecipient's capitalization level for financial statement purposes, or $10,000 per unit (useful life > 1 year).

Scope & Exam Trap: Watch the 'lesser of' rule: if an institution keeps a $5,000 financial-statement capitalization threshold, its federal equipment threshold remains $5,000 until institutional policy and NICRA implementation are updated.

Practice Topic 3.07 (2024 Revision items) →

Thresholds & MTDC · 2 CFR 200.314(a)

Read 2 CFR 200.314(a) on eCFR ↗

Residual unused supplies disposition at closeout

Pre-2024 Uniform Guidance

Compensation to the federal agency required if residual inventory of unused supplies exceeds $5,000 in total aggregate value at closeout (and is not needed for another federal award).

2024 Revised Rule (Oct 1, 2024)

Compensation to the federal agency required if residual inventory of unused supplies exceeds $10,000 in total aggregate value at the end of the period of performance.

Scope & Exam Trap: Unlike equipment (measured per unit), the $10,000 unused-supplies disposition threshold in 200.314(a) is measured in the aggregate across all residual unused supplies.

Practice Topic 3.07 (2024 Revision items) →

Thresholds & MTDC · 2 CFR 200.1 (MTDC)

Read 2 CFR 200.1 (MTDC) on eCFR ↗

Subaward inclusion cap in Modified Total Direct Costs (MTDC)

Pre-2024 Uniform Guidance

MTDC includes up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award).

2024 Revised Rule (Oct 1, 2024)

MTDC includes up to the first $50,000 of each subaward (regardless of the period of performance of the subawards under the award).

Scope & Exam Trap: Applies separately to each subaward across its entire life under the prime award (not $50,000 per budget year). Existing awards/NICRAs may still specify the $25,000 threshold until renegotiated.

Practice Topic 3.06 (2024 Revision items) →

Thresholds & MTDC · 2 CFR 200.414(f)

Read 2 CFR 200.414(f) on eCFR ↗

De minimis indirect cost rate

Pre-2024 Uniform Guidance

10% of Modified Total Direct Costs (MTDC) for eligible entities that do not have a current negotiated indirect cost rate.

2024 Revised Rule (Oct 1, 2024)

Up to 15% of Modified Total Direct Costs (MTDC) for recipients and subrecipients that do not have a current federal negotiated indirect cost rate (including a provisional rate).

Scope & Exam Trap: An entity with an active federally negotiated rate cannot elect the 15% de minimis rate, and federal agencies or pass-through entities cannot force a subrecipient without a negotiated rate to accept less than 15% unless required by statute or regulation.

Practice Topic 3.06 (2024 Revision items) →

Closeout, Audit & Records · 2 CFR 200.501(a)

Read 2 CFR 200.501(a) on eCFR ↗

Single Audit / Program-Specific Audit expenditure threshold

Pre-2024 Uniform Guidance

$750,000 or more in federal awards expended during the non-federal entity's fiscal year.

2024 Revised Rule (Oct 1, 2024)

$1,000,000 or more in federal awards expended during the non-federal entity's fiscal year.

Scope & Exam Trap: Triggered by federal funds expended (not total dollars awarded) during the fiscal year, effective for audits of fiscal years beginning on or after October 1, 2024.

Practice Topic 3.05 (2024 Revision items) →

Subawards & Pass-Through · 2 CFR 200.333

Read 2 CFR 200.333 on eCFR ↗

Fixed-amount subaward maximum ceiling

Pre-2024 Uniform Guidance

With prior written approval from the federal awarding agency, a pass-through entity could provide fixed-amount subawards up to the Simplified Acquisition Threshold ($250,000).

2024 Revised Rule (Oct 1, 2024)

With prior written approval from the federal agency, a pass-through entity may provide subawards based on fixed amounts up to $500,000, provided the subawards meet the requirements of 2 CFR 200.201.

Scope & Exam Trap: Do not confuse fixed-amount subawards under 200.333 ($500,000 cap + prior federal agency approval) with federal prime fixed-amount awards under 200.201(b) (which do not have the $500,000 cap).

Practice Topic 1.11 (2024 Revision items) →

Subawards & Pass-Through · 2 CFR 200.344(a)

Read 2 CFR 200.344(a) on eCFR ↗

Subrecipient final report submission timeline

Pre-2024 Uniform Guidance

Subrecipient had to submit all final reports to the pass-through entity no later than 90 calendar days (or an earlier date as agreed upon by the PTE and subrecipient) after the period of performance end date.

2024 Revised Rule (Oct 1, 2024)

Clarifies that a subrecipient must submit all required final financial, performance, and other reports to the pass-through entity no later than 90 calendar days after the conclusion of the subaward period of performance (or an earlier date as agreed upon).

Scope & Exam Trap: Recipient prime reports are due within 120 calendar days; the default subrecipient rule in 200.344(a) is 90 calendar days unless the subaward agreement specifies an earlier deadline (such as 45 or 60 days).

Practice Topic 1.12 (2024 Revision items) →

Closeout, Audit & Records · 2 CFR 200.344(h)–(i)

Read 2 CFR 200.344(h)–(i) on eCFR ↗

Federal agency 1-year closeout window & SAM.gov reporting

Pre-2024 Uniform Guidance

Framed around completing closeout actions within one year of receipt and acceptance of all required final reports.

2024 Revised Rule (Oct 1, 2024)

The federal agency must complete all closeout actions no later than one year after the end of the period of performance. If the recipient fails to submit all required final reports within one year of the period of performance end date, the agency must report the material failure in SAM.gov.

Scope & Exam Trap: The one-year clock runs from the end of the period of performance, not from whenever the recipient submits late reports.

Practice Topic 1.12 (2024 Revision items) →

Prior Approvals & Direct Costs · 2 CFR 200.413(c)

Read 2 CFR 200.413(c) on eCFR ↗

Direct charging of administrative and clerical salaries

Pre-2024 Uniform Guidance

Required four conditions: (1) integral to a project/activity, (2) individuals can be specifically identified with the project/activity, (3) explicitly included in the budget or have prior written approval of the federal awarding agency, and (4) the costs are not also recovered as indirect costs.

2024 Revised Rule (Oct 1, 2024)

Retains the requirement that administrative/clerical salaries are normally indirect, and may be direct-charged only if (1) integral to a federal award, (2) individuals can be specifically identified with the federal award, and (3) explicitly included in the budget or have the prior written approval of the federal agency (and not also recovered as indirect costs).

Scope & Exam Trap: The 2024 revision did NOT eliminate the requirement that direct administrative/clerical salaries be explicitly included in the budget or have prior written approval from the federal agency.

Practice Topic 3.01 (2024 Revision items) →

Prior Approvals & Direct Costs · 2 CFR 200.1, 200.308(f)(5) & 200.456

Read 2 CFR 200.1, 200.308(f)(5) & 200.456 on eCFR ↗

Participant support costs definition & prior approval

Pre-2024 Uniform Guidance

Direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences or training projects.

2024 Revised Rule (Oct 1, 2024)

Clarifies that participant support costs are direct costs for items such as stipends, subsistence allowances, travel allowances, registration fees, temporary dependent care, and per diem paid to or on behalf of participants (not employees) in connection with conferences or training projects; transferring funds out of participant support costs to other budget categories still requires prior federal agency approval under 200.308(f)(5).

Scope & Exam Trap: Employees of the recipient organization can never be funded as participants under participant support costs, and participant support costs are always excluded from the MTDC base.

Practice Topic 3.01 (2024 Revision items) →

Thresholds & MTDC · 2 CFR 200.306(k)

Read 2 CFR 200.306(k) on eCFR ↗

Voluntary uncommitted cost sharing

Pre-2024 Uniform Guidance

Addressed primarily through OMB memorandum M-01-06 and agency policy (such as NSF PAPPG) for faculty research effort over and above committed levels.

2024 Revised Rule (Oct 1, 2024)

Codifies directly in 2 CFR 200.306(k) that voluntary uncommitted cost sharing must be excluded from the institution's effort and F&A rate calculations in accordance with applicable cost principles.

Scope & Exam Trap: Voluntary committed cost sharing (pledged in the proposal budget/justification) is binding and auditable; voluntary uncommitted cost sharing (extra unpledged effort after award) is neither tracked for sponsor reporting nor included in the F&A base.

Practice Topic 3.02 (2024 Revision items) →

Closeout, Audit & Records · 2 CFR 200.419

Read 2 CFR 200.419 on eCFR ↗

CASB Disclosure Statement (DS-2) for Institutions of Higher Education

Pre-2024 Uniform Guidance

Required an IHE that received aggregate federal awards totaling $50 million or more in a fiscal year to submit a Cost Accounting Standards Board Disclosure Statement (DS-2).

2024 Revised Rule (Oct 1, 2024)

Eliminates the mandatory requirement in 200.419(b) for institutions of higher education reaching the $50 million threshold to submit a federal DS-2.

Scope & Exam Trap: IHEs remain subject to the cost accounting standards referenced in 200.419(a) (consistency in estimating, accumulating, and reporting costs, and consistency in allocating costs incurred for the same purpose), even though the DS-2 filing mandate was removed.

Practice Topic 3.06 (2024 Revision items) →

Always check the award terms and NICRA

While OMB set October 1, 2024 as the government-wide effective date for the 2024 revisions to 2 CFR Part 200, individual awards and Negotiated Indirect Cost Rate Agreements (NICRAs) govern how and when specific thresholds (such as the $50,000 subaward MTDC cap or the $10,000 equipment capitalization ceiling) apply to a given project.

Read our full guide, What the 2024 Uniform Guidance Revisions Change in Day-to-Day Grant Administration, or test yourself with Before Memorizing a Threshold, Check Its Date and Scope.