Uniform Guidance (2 CFR 200) quick reference

What is the Uniform Guidance?

The Uniform Guidance is the common name for 2 CFR Part 200, "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards." Issued by the Office of Management and Budget (OMB), it replaced several older OMB circulars, including A-21 for universities and A-133 for audits, with one rulebook for federal grants and cooperative agreements.

It covers the whole life of an award: how agencies announce and make awards, what recipients may charge, how indirect costs work, procurement, equipment, subrecipient monitoring, reporting, closeout, and the single audit. Most institutional policies on cost allowability, effort, and purchasing trace back to it. It is the backbone of grants management for any organization receiving federal funds.

Current status (October 2026)

2024 Uniform Guidance threshold changes

The 2024 revision, published April 22, 2024, was the first major revision since the Uniform Guidance took effect in 2014. Most of its changes simplify administration, and several raise dollar thresholds that had not moved in a decade.

Where NIH differs

NIH adopted the 2024 thresholds in 2025, then reversed course. Citing the FY2026 appropriations act, NIH notice NOT-OD-26-072 (April 20, 2026) rescinded the 2024 definition of modified total direct costs and the 15% de minimis rate for NIH awards, and stated that NIH "will not apply updated thresholds outlined within 2 CFR Part 200, at this time." Indirect costs on NIH awards follow the HHS rules in 45 CFR 75.

Subawards and the $25,000 rule

The subaward rule decides how much of each subaward carries your institution's indirect costs. Only the first $25,000 of each subaward goes into the modified total direct cost (MTDC) base, counted once over the life of the subaward, not each year. Anything above $25,000 is excluded from the base, because the subrecipient charges its own indirect costs on that work.

Use $25,000 for every NIH budget. For other agencies, use $25,000 unless your negotiated rate agreement adopts the 2024 amount of $50,000; some institutions have moved to $50,000 for non-NIH awards and others have not. The F&A and MTDC calculator defaults to $25,000 and can be switched.

Key sections of 2 CFR 200

The sections research administrators cite most often:

The proposed 2026 rewrite: the Uniform Grants Regulation

On May 29, 2026, OMB published a proposed rule, "Regulation for Federal Financial Assistance," that would rename 2 CFR 200 the Uniform Grants Regulation and make it binding regulation rather than guidance. It keeps the existing section numbering. Among the proposed changes: clearer authority for agencies to terminate discretionary awards when that is in the agency's interest, the elimination of fixed amount awards and subawards, new disclosures about former agency employees who worked on a proposal, and a pre-issuance review of awards. OMB said it did not propose changes to the indirect cost rate negotiation system.

Comments closed July 13, 2026, and OMB had targeted October 1, 2026 for a final rule. The continuing resolution signed September 2, 2026 bars OMB from issuing or finalizing the rule, or a substantially similar one, through December 11, 2026. Until a final rule is published, the 2024 Uniform Guidance and agency terms such as NIH's continue to apply.