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While OCI “requirements are applicable to most procurements, acquisitions below the simplified acquisition threshold (SAT) and those for commercial products are exempt, as well as subcontracts for commercial products or commercial services.” ” Use of “structural or behavioral barriers, internalcontrols, or both.”
Tom Temin Sure, and there are also some updated thresholds for what gets audited, what gets investigated by the government, and also for some of the provisions for equipment and ancillary costs associated with a grant. Let’s talk about maybe the threshold for what gets audited. What are some of the top ones there? Dan Ramish Yes.
On April 22, 2024, the Office of Management and Budget (OMB) issued a Final Rule significantly revising the Uniform Guidance for grants, cooperative agreements, and other federal financial assistance. Agencies must implement the Final Rule by October 1, 2024; however, agencies may apply it to federal awards as early as June 21, 2024.
The standard for reasonableness depends on whether the compensation is paid in accordance with an “arm’s length” labor-management agreement negotiated pursuant to the Federal Labor Relations Act or similar state statutes. [9] 14] Compensation is reasonable if the total of each measurable and allowable element sums to a reasonable total. [15]
Only a few organizations can afford this, typically those with diverse tasks that allow managers to continually enhance their data analysis skills and the market salary to retain skilled specialists. Recently, TI Ukraine found an interim solution that combines the flexibility of ProBI with a low “entry threshold.”
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