Award Recipient FAQs

Find answers to questions grantees, like you, ask us.

Topics

• 2 CFR part 200 and HHS Grants Policy Statement
• Contact Information
• Mandatory Registrations
• Application Scoring & Decisions
• Prior Approval Requests
• Costs
• Reporting
• Closeout
• Login/Password Reset

2 CFR part 200 and HHS Grants Policy Statement

The Department of Health and Human Services (HHS) published two updates that went into effect on October 1, 2024.

1. Interim Final Rule (IFR) Health and Human Services Adoption of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards with a phased plan for adopting 2 Code of Federal Regulations (CFR) part 200.
2. HHS Grants Policy Statement (GPS) (PDF - 1 MB) - Read the September 27, 2024, press release about the changes.

Q: What’s the Interim Final Rule (IFR)? How does it affect me?

A: The Office of Management and Budget (OMB) updated the Uniform Guidance with the effective date of October 1, 2024.

The IFR announced a phased approach to implement 2 CFR part 200 (Uniform Guidance), and delays the date it goes into effect to October 1, 2025. This is true for all provisions of 2 CFR part 200 and HHS-specific changes to 2 CFR part 300. This delay allows HHS agencies time to make these changes.

Increases to monetary thresholds

These eight changes will reduce burden for anyone who applies for, and receives, HHS grants.

1. Exclusion threshold of subawards from $25,000 to $50,000 for modified total direct cost calculations (2 CFR § 200.1 definition of Modified Total Direct Cost)
2. Equipment threshold from $5,000 to $10,000, and clarification that Indian tribes may use their own procedures for equipment disposition (2 CFR § 200.313(e))
3. Supply threshold from $5,000 to $10,000 (2 CFR § 200.314(a))
4. Amount of fixed amount subawards that a recipient may provide with prior written approval from the agency to $500,000 (2 CFR § 200.333)
5. Indirect cost de minimis rate from 10% to 15% (2 CFR § 200.414)
6. Single audit threshold from $750,000 to $1 million (2 CFR § 200.501)

Already adopted provisions

1. Increased micro-purchase threshold to $50,000 (2 CFR § 200.320)
2. Allows 120 days after the period of performance to submit all final reports related to award closeout (2 CFR § 200.344) (Change in Federal Award Closeout Provisions)

Q: Do you still require recipients to follow 45 CFR part 75?

A: Yes. Aside from the eight changes from 2 CFR part 200, HHS continues to follow 45 CFR part 75 and will do so until September 30, 2025.

As the IFR outlines, on October 1, 2025, HHS will fully adopt 2 CFR part 200 along with 12 HHS-specific modifications in 2 CFR part 300.

In summary:

October 1, 2024 – Follow 45 CFR part 75 and the eight (8) threshold changes from 2 CFR part 200.

October 1, 2025 – Follow 2 CFR part 200 and the 12 HHS-specific modifications at 2 CFR part 300.

Q: What are the HHS-specific modifications at 2 CFR part 300?

A: Read the 12 modifications in the CFR. Or view them in appendix 2 of our Grants Policy Bulletin – Adopting 2 CFR part 200 and the HHS GPS (PDF - 83 KB).

Q: Can we rebudget to reflect the eight changes to the new monetary thresholds?

A: Yes, you may do this. This also includes the new de minimis rate of 15%.

If the request exceeds 25% of total costs or $250,000, whichever is less, of the most recently approved budget period, you must request prior approval through HRSA’s Electronic Handbooks (EHBs).

Q: What did HHS change with this GPS update?

A:

• Using plain language in Grants Policy Statements. The Plain Writing Act of 2010 (Public Law 111-274) requires federal agencies to write clear documents for the public.
• Added flexibility for the grant community aligning with HHS adopting 2 CFR part 200.
• Indirect cost policy to reflect the Executive Level II salary cap now applies to both direct and indirect costs.

Q: Does the revised HHS GPS apply to all awards, or only those issued after October 1, 2024?

A: As of October 1, 2024, HRSA and recipients must follow the updated HHS GPS for all new and active awards.

Q: When will HHS update the GPS in the future?

A: They plan to update it every year and will update it again before September 30, 2025.

The 2025 update will reflect the adopting of 2 CFR part 200 for all awards HHS makes on or after October 1, 2025.

Q: You issued our award before October 1, 2024. Do we need to report on equipment using the $5,000 threshold from 45 CFR part 75?

A: No. You should follow 2 CFR 200.313 which increases the value of equipment from $5,000 to $10,000 and that at the end of the grant period “may be retained, sold, or otherwise disposed of with no further responsibility to the federal agency” (see 2 CFR section 200.313(e)(1)).

The provision also clarifies that Indian tribes may use their own procedures for using, managing, and disposing equipment. If they do not have procedures, then they must follow the ordinary guidance.

Q: Our award expired before October 1, 2024. Do we need to follow the $5,000 threshold for any unused supplies from 45 CFR part 75?

A: Yes. You should use the previous $5,000 threshold listed in 45 CFR part 75. Awards that are active as of October 1, 2024, will follow the new provisions at 2 CFR § 200.314(a), which increased the supply threshold to $10,000.

Q: When does the Single Audit Threshold increase for my organization?

A: As part of OMB’s revised Uniform Guidance, the Single Audit threshold increased from $750,000 to $1,000,000.

For fiscal years beginning on or after October 1, 2024, HHS now requires single audits for any recipient that expends $1,000,000 or more in federal awards within its fiscal year.

For example, if your fiscal year is December 1, 2023, through November 30, 2024, you’re subject to the new single audit threshold of $1,000,000 beginning December 1, 2024, as the fiscal year starts after October 1, 2024 (the date on which the revised Uniform Guidance now applies).

Q: Will we see any changes to our HRSA award documents?

A: No, we will not change your Notice of Award (NoA). However, the NoA will lay out the General Terms and Conditions (PDF - 120 KB) which we updated to reflect the 2024 HHS GPS and HHS’s phased adoption of 2 CFR part 200.

Contact Information

Mandatory Registrations

Q: How often should I update my System for Award Management (SAM) record?

A: You must update your registration in the System of Award Management (SAM.gov) every year. Your renewal can take five days or longer.

Application Scoring & Decisions

Q: Will my application receive a perfect score if there are no weakness comments in the summary statements?

A: No. Strengths and weaknesses comments do not carry the same weight. Even without any weakness comments, an application may not receive a perfect score.

These comments are judgments from our panel of grant reviewers. Reviewers judge each portion of your application against scoring guidelines we provide them.

Q: Does an application receive a perfect score if there are no weakness comments in the summary statements?

A: The absence of a weakness comment does not indicate a perfect score. Not all strengths and weakness comments carry the same weight; therefore, the quantity of weakness comments does not affect the score.

Summary statement comments produced from the panel discussion reflect the considerations and judgments of the expert reviewers within the panel.

We provide reviewers with a “Scoring Rubric” that aligns descriptive ranges to precise scoring guidelines for each criterion and overall score.

Q: Can I appeal the Objective Review Committee (ORC) decision?

A: Award decisions are discretionary and are not subject to appeal to any HRSA or HHS official or board.

However, the appropriate contact identified on your notification letter can provide further clarification surrounding the summary statement and the objective review process.

Prior Approval Requests

Q: What is a Prior Approval Request? Why would I use it?

A: You would submit a written request for prior approval if you wish to make adjustments to the budget, and/or program plans on the objectives or purpose of the approved project. You must submit this request through the EHBs.

Q: How do I create, edit or find a prior approval request?

A: Follow our instructions within the EHBs to create, edit, or find a prior approval request.

Costs

Q: Where can I find more information on Cost Principles?

A: Please refer to 45 CFR Part 75 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, Subpart E – Cost Principles.

Q: What is the difference between an allowable cost, an allocable cost, and a reasonable cost?

A:

• An allowable cost complies with the terms, conditions, and approved activities of the grant, as well as Cost Principles.
• An allocable cost can apply to multiple activities. It provides a direct benefit to award objectives. Example: rent or utilities.
• A reasonable cost is necessary and appropriate for the activity.

Q: How can I avoid unallowable costs?

A: Check our tip sheet: Developing Effective Financial Management Practices (PDF - 209 KB).

Q: I need to return funds. How do I do it?

A: Get instructions from the Program Support Center’s Payment Management System (PMS).

Q: How do you define an allowable cost, an allocable cost, and a reasonable cost?

A: An allowable cost is a cost that is charged to the grant that complies with the terms, conditions and approved activities of the grant, as well as the Cost Principles for Federal awards.

An allocable cost is a cost that is for multiple activities where a portion is allocated to the grant that is in relation to the benefit received (like rent or utilities).

A reasonable cost is a cost that a reasonable person would approve of charging to the grant that is appropriate for the activity.

Q: How can I avoid having Unallowable Costs?

A: Check our tip sheet: Developing Effective Financial Management Practices (PDF - 209 KB).

Reporting

Q: Do I have to submit an Annual Performance Report?

A: Yes. Review your Notice of Award (NoA) for specific requirements. Contact your PO with questions.

Q: When the GMS returns my FFR, what do I do?

A: Review the comments and make the required changes. You can also respond with any questions.

Q: Where do I submit my Federal Financial Report (FFR)?

A: All expenditure reporting previously submitted to HRSA via the Federal Financial Report (FFR) is being consolidated into one form (SF-425) and will be submitted through the Payment Management System starting October 1, 2020. recipients will no longer submit financial expenditure data through awarding agency systems such as the EHBs.

Q: How are FFR due dates determined?

A: HRSA FFRs are aligned with the PMS quarterly reporting due dates and are as follows:

• Budget Period ends August, September, October: FFR due January 30
• Budget Period ends November, December, January: FFR due April 30
• Budget Period ends February, March, April: FFR due July 30
• Budget Period ends May, June, July: FFR due October 30
• Questions about the FFR due dates should be directed to the Grants Management Specialist.

Q: Will recipients have access to view submitted FFRs from the EHBs?

A: Although you will submit all FFRs through PMS starting in October 2020, you will see a read-only version of the FFR from the HRSA Electronic Handbooks.

Q: How do I request an extension to my FFR?

A: The ability to "Request an Extension" to the FFR within the EHBs will no longer be available. While PMS is working on an enhancement to allow extensions to be requested through the system in the near future, you should make every effort to submit FFRs by the deadline. If unforeseeable circumstances arise that prevent you from submitting your FFR on time, please reach out to your Grants Management Specialist. You will still be able to request extensions to other submissions (e.g., progress reports) from the EHBs.

Q: I need to revise my expenditures on an approved FFR. How can I make this change?

A: Once the FFR migration has taken place, you will identify changes to prior expenditures in the cumulative expenditure field of the most current FFR available in PMS. You will use the Remarks to specify:

• the value;
• the budget period the change corresponds to; and
• the reason for the change.

The FFR may be rejected if you do not provide sufficient information regarding the change.

Q: Whom should I contact if I have questions about submitting the FFR in PMS?

A: You can send your Questions about the FFR integration into PMS - including system access, functionality, or technical support - to PMSFFRSupport@psc.hhs.gov.

For general PMS questions, you can contact the PMS Help desk via email or phone, or a Self Help Portal is available on the PMS website.

Q: Do you always require that I submit an Annual Performance Report? 

A: Every grant award requires an annual performance report. Review your Notice of Award (NoA) for any specific requirements. Contact your PO with any questions.

Closeout

Q: How long do I have to submit final reports and liquidate funds from PMS after my grant ends?

A: We follow the closeout provisions at 2 CFR 200.344. HRSA recipients have 120 days to liquidate all financial obligations and submit final reports.

Q: Who do I contact with questions about the face page or standard terms in the Notice of Award (NOA), the Federal Financial Report (FFR) and/or the Tangible Personal Property reporting requirements?

A: Contact your Grants Management Specialist (GMS). You can find their contact information in the contacts section in the Electronic Handbooks (EHBs) or on the last page of your Notice of Award (NOA).

Q: Who do I contact with questions about programmatic issues, program terms or conditions on the Notice of Award (NOA), or Performance, Progress, or Program Specific Reports (not including the FFR)?

A: Contact your Project Officer. Their contact information can be found in the contacts section of the EHB, or on the last page of your Notice of Award (NoA). You can also find your Project Officer on bureau/program specific pages. Start here at HRSA.gov.

Q: How long after my grant ends do I have to drawdown funds from PMS?

A: A non-federal entity must liquidate all obligations incurred under the award no later than 90 days after the end of the funding period.

We may extend this deadline, but you must first have prior written approval from the HRSA Grants Management Specialist listed on the last page of the Notice of Award.

Refer to 45 CFR 75.309 - Period of performance and availability of funds.

However, the appropriate contact identified on your notification letter can provide further clarification surrounding the summary statement and the objective review process.

Login/Password Reset

Q: Who do I contact if I am locked out of the Electronic Handbooks (EHBs)?

A: The EHBs allows you to retrieve or reset your password – follow these instructions. If you have forgotten your username, contact us.