| USAID’s Early Implementation of 2024 Revisions to 2 CFR | Guidance for USAID’s Early Implementation of 2024 Revisions to 2 CFR | USAID Letter |
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August 8, 2024
Subject: USAID’s Early Implementation of 2024 Revisions to 2 CFR
Dear USAID Recipients,
The purpose of this letter is to alert you to USAID’s early implementation of significant revisions
to U.S. federal financial assistance regulations. The Office of Management and Budget (OMB)
published revisions to Title 2 of the Code of Federal Regulations (2 CFR) (“2024 Revisions”) in
April 2024. OMB set the government-wide effective date of the 2024 Revisions as October 1, 2024. However, Federal agencies may implement the 2024 Revisions prior to that date, and
USAID is choosing to do so.
As described in previous communications and this blog, USAID is excited about the 2024
Revisions which clarify and simplify requirements for federal financial assistance, reduce
burdens on USAID staff and partners, and provide new flexibilities that support the
Agency’s localization initiative. USAID is electing to implement the 2024 Revisions prior to the
government-wide effective date of October 1 in order to maximize the benefits for Agency
awards, especially those awarded or amended during the last few months of the fiscal year.
The Agency is implementing the 2024 Revisions via Acquisition and Assistance Policy Directive
(AAPD) 24-06. The AAPD includes, among other things, temporary, interim standard provisions
that make the new flexibilities immediately available for Agreement Officers (AOs) to include in
new and existing awards, as applicable.
For existing awards, USAID AOs may negotiate bilateral award amendments with recipients to
include the 2024 Revisions if amending the award is beneficial to the program, recipient, and
USAID. When deciding whether to amend an award to incorporate the 2024 Revisions, AOs will
consider:
● The availability of funds and other budget implications;
● The remaining period of performance; and
● Explicit requests from recipients, regardless of the remaining period of performance.
Note: Contractors cannot apply the 2024 Revisions to grants under contracts (GUCs) until the
revisions are fully implemented in ADS 303, including the standard provisions (i.e., 303maa,
303mab, and 303mat). The 2024 Revisions are not applicable to GUCs prior to October 1, 2024
or the date of the amendment to the GUC, whichever is later.
Recipient Implementation of 2024 Revisions
Recipients are only required to comply with the 2024 Revisions for awards issued or amended
to include revised standard provisions. Recipients may simultaneously be implementing multiple
USAID awards, some of which incorporate updated provisions and some which do not.Thus
recipients should be aware that not all flexibilities made available under the 2024 Revisions will
be available under the terms and conditions of earlier awards, unless amended.
Additionally, recipients may only issue or amend subawards to include the 2024 Revisions if
those revisions are already included in the prime award. If a prime award is amended to include
revised provisions, then the recipient should
also amend any existing subawards to
incorporate the revisions. Subaward
amendments should be completed as soon as
practicable to maximize the availability of new
flexibilities for subrecipients.
USAID recognizes the interest of the partner
community in the 2024 Revisions and USAID’s
early implementation. During the fourth quarter
of the fiscal year, when both recipient
organizations and USAID staff are busy
finalizing awards, the Agency is prioritizing
providing guidance to its AOs and other A&A
staff. Early in Fiscal Year 2025, USAID will
consider a webinar or other additional communications with partners on implementation of the
2024 Revisions.
If you have any questions regarding how the 2024 Revisions may apply to a Notice of Funding
Opportunity, award, or subaward, please contact the cognizant AO or prime recipient,
respectively.
Sincerely,
Jami J. Rodgers, CPCM
USAID Senior Assistance Executive and
Director, Bureau for Management, Office of Acquisition & Assistance