June 04, 2024
OMB Revises its Uniform Grants Guidance, Clarifying Support for Program Evaluation
By The Evidence Team, OMB
The Office of Management and Budget (OMB) issues guidance in Title 2 of the CFR, often referred to as the Uniform Grants Guidance, that represents government-wide policies for the award and administration of Federal financial assistance. This guidance provides a common framework for how more than 1.2 trillion dollars are spent by recipients of Federal funds, including grants. An updated version of this guidance was released in April 2024. The Uniform Grants Guidance 2024 Revision clarifies that evaluation is a supported activity of agencies and award recipients, and the guidance emphasizes that recipients are allowed to spend a portion of award funding on evaluation activities related to the award.
Evaluation is an important priority and a key agency function within the Federal Government. Evaluation allows agencies and grant recipients to better understand the extent to which intended goals are being achieved, beyond performance reporting and grant monitoring. Evaluation can address questions related to grant implementation, the effectiveness or impact of specific strategies used in grant activities, and questions related to understanding the important context for results achieved or a deeper understanding of outcomes across various groups served. Evaluation can provide results to help agencies and grant recipients learn what works, for whom, and under what circumstances. Award recipients are able to use a portion of award funds for a broad range of evaluation activities including evidence reviews, evaluation planning and feasibility, assessment, conducting evaluations, and more.
Agencies issuing Federal awards and organizations receiving a Federal award should review the Uniform Grants Guidance 2024 Revision, which:
- emphasizes that Federal agencies should consider available evidence and evaluation results (from past programs) as part of designing and planning assistance programs (see 2 C.F.R. § 200.202). Additionally, organizations applying for a Federal award may consider evidence in planning their proposed award activities;
- clarifies that agencies can require award recipients to participate in federally-funded evaluations (see 2 C.F.R. § 200.301, § 200.503);
- confirms that, when related to a Federal award, recipients can use some of the award funding to undertake activities and cover expenditures necessary to build high quality evidence through their organization’s own evaluation or an evaluation led by a Federal agency (see 2 C.F.R. § 200.413, § 200.455); these may include (but are not limited to) costs of gathering data, managing data systems, and building integrated data systems that link individual-level data from multiple State and local government agencies for purposes of management, research, and evaluation;
- explains that agencies should consider evaluation activities when determining reporting requirements for Federal awards (see 2 C.F.R. § 200.329);
- allows agencies to request exceptions from OMB on particular provisions of the Uniform Grants Guidance to support innovative programs designs (see 2 C.F.R § 200.102) that could be further supported and tested through evaluation (see 2 C.F.R § 200.301);
- clarifies that the Uniform Grants Guidance should not be interpreted as limiting the authority of agencies to conduct or arrange for program evaluation (see 2 C.F.R § 200.503); and
- encourages cross-agency collaboration when planning grants, particularly when the goals and objectives of a grant program align with those of other agencies (see 2 C.F.R § 200.202).
More information about supports for evaluation and allowable costs for evaluation activities are available in reference guides issued by OMB as well as the OMB Uniform Grants Guidance 2024 Revision.
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