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Dear Partners,
USAID encourages all members of the partner community to review this Proposed Rule and provide comments to the Office of Management and Budget (OMB) on proposed revisions to various parts of 2 CFR. These revisions include updates to 2 CFR 200 (Uniform Guidance), 2 CFR 175 (Award Term for Trafficking in Persons), 2 CFR 170 (Reporting Subaward and Executive Compensation Information), and 2 CFR 25 (Universal Identifier and System for Award Management). Your practical experience in implementing assistance awards overseas will provide useful feedback to OMB to enhance the proposed revisions.
We previously shared the Request for Information that OMB used to collect initial feedback from the public. Based on the comments received from the public and further dialogue with agencies, OMB published the above-linked rule with proposed revisions to 2 CFR, and now seeks additional comments from the public. In accordance with OMB guidance for Broadening Public Participation and Community Engagement in the Regulatory Process, we encourage USAID’s partner community to submit comments following the procedures outlined in the rule.
As you review the proposed rule, please note that OMB’s objectives for these revisions include: (1) incorporating statutory requirements and administration priorities; (2) reducing agency and recipient burden; (3) clarifying sections that recipients or agencies have interpreted in different ways; and (4) rewriting applicable sections in plain language, improving flow, and addressing inconsistent use of terms.
OMB invites comments on any of the proposed revisions to 2 CFR. In the rule’s preamble, OMB identifies several areas throughout 2 CFR where comments may be particularly useful. OMB also requests input on whether any of the plain language revisions may have unintended consequences, and seeks comments on whether further modifications or additional precision is needed in any specific instance. In addition, OMB notes it is considering other ways of reducing the administrative burden associated with obtaining a UEI and registering in SAM.gov.
Direct feedback to OMB from USAID’s partners will ensure the updates to the 2 CFR regulations reflect the needs and priorities of our international humanitarian assistance and development work. Please note that comments are due on December 4, 2023. The “Addresses” section of the proposed rule contains detailed instructions regarding the process for submitting public comments. For your reference in reviewing the updates, OMB also posted a redline version of the changes on CFO.gov.
Thank you for taking the time to offer your comments.
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