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ACL reiterates full adoption of 2 CFR 200; highlights higher audit and equipment thresholds
Summary
ACL presenters told grantees that HHS has fully adopted 2 CFR 200 with HHS-specific provisions in 2 CFR 300, effective Oct. 1, 2025, and flagged threshold changes including a $1 million single-audit threshold, $10,000 equipment and supply thresholds, and a 15% de minimis indirect cost rate.
The Administration for Community Living used its webinar to remind Older Americans Act grantees of recent regulatory changes and practical implications for grant management.
Stephanie Cole, program administrator in the Administration on Aging, summarized HHS’s codification: "with the complete adoption of 2 CFR 200 alongside 12 HHS specific provisions retained in 2 CFR 300 to be fully effective on October 1st, 2025," she said. Cole highlighted four threshold changes attendees should note: an increased single-audit threshold to $1 million; an equipment threshold of $10,000; an increased threshold for supplies to $10,000; and a de minimis indirect cost rate increased to 15%.
Cole reminded attendees these are part of uniform guidance (2 CFR 200) and that allowable cost criteria still require that costs be necessary, reasonable, allocable, consistently treated and adequately documented. She emphasized documentation and internal controls as front-line defenses against audit findings and ineligible costs.
The presenters urged grantees to review NOAs carefully and to track cumulative grant awards and amendments; they also illustrated a sample grant-number schema to help recipients identify fiscal year, entity, state, program code and version digits on award documents. ACL’s implementation web page and the two CFR texts were listed as resources to help grantees update internal processes and ensure compliance with the new thresholds.
