Ed Dept Retroactively Updates Federal Grant Guidance Rules
Published Date: 2/10/2025
Notice
Summary
Starting February 10, 2025, the Department of Education is updating its grant rules to match the 2024 federal financial guidance, but only going back as far as June 21, 2024. This change affects all current and past grants under these rules, clearing up confusion from an earlier January update. Grant recipients should expect clearer terms with no surprise costs or deadlines beyond what’s already set.
Analyzed Economic Effects
4 provisions identified: 3 benefits, 1 costs, 0 mixed.
Retroactivity cutoff clarified
If you receive a Department of Education grant, the Department says the April 22, 2024 revision to the Uniform Guidance only applies to grants awarded on or after October 1, 2024. The Department is withdrawing its January 16, 2025 notice and this clarification is effective February 10, 2025 and applies to all Department grants subject to the Uniform Guidance.
Which version of 2 CFR part 200 applies
The Department changed Box 10 of its Grant Award Notices so that: (i) grants issued on or after October 1, 2024 are governed by Title 2 CFR part 200 as revised at 89 FR 30136-30208 (April 22, 2024); and (ii) grants issued before October 1, 2024 are governed by the version of the Uniform Guidance in effect at the time of the award.
Limited retroactivity for June 21–Oct 1 grants
There is a specific exception: for grants issued on or after June 21, 2024 (but before October 1, 2024), if a grantee drew down funds under the previous version of Box 10, then that grant is subject to the April 22, 2024 revised Title 2 CFR part 200.
No action required; notice supersedes prior GANs
You do not have to take any action because the Department says grantees are not required to get a new printed Grant Award Notice. The revised Box 10 and this February 10, 2025 notice supersede previous GANs or notices, and the Department encourages keeping a copy of this notice in grant files.
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Key Dates
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