UG Revisions Published: 2 Provisions Effective Immediately

Fri, 14 Aug 2020 10:56:26 -0400

OMB published revisions to Uniform Guidance yesterday; provisions in the revised guidance will apply to awards issued after its effective date, November 12th, 2020. However, there are two provisions in the revised guidance that went into effect yesterday: §200.216, Prohibition on certain telecommunications and video surveillance services or equipment, and §200.340, Termination. Summaries of these two revisions are summarized below but can be read in their entirety in Final Guidance posted in the Federal Register linked to this post. OSP will provide a summary of the revisions going into effect in November in a separate post.

The new provision at §200.216 states that “recipients and subrecipients are

prohibited from obligating or expending loan or grant funds to: (1) procure or

obtain; (2) extend or renew a contract to procure or obtain; or (3) enter into a

contract (or extend or renew a contract) to procure or obtain equipment, services or

systems that use(s) covered telecommunications equipment or services as a

substantial or essential component of any system, or as critical technology as part

of any system.”

The termination provision at §200.340 now eliminates the current “for cause”

reason for termination and replaces it with one stating that an award may be

terminated “if an award no longer effectuates the program goals or agency

priorities.” In addition, federal awarding agencies must make recipients aware, in a

clear and unambiguous manner, of the termination provisions in §200.340.