OMB Uniform Guidance Implementation Report

By completing this form, you are helping the network of the National Council of Nonprofits monitor compliance, compile data and patterns that can be addressed at a government-wide level, and identify good processes and solutions that can be replicated to help nonprofits across the country. The National Council of Nonprofits is not a regulatory body and can not intervene in specific situations. The information you share below – whether positive or negative – will help build the evidence for best practices and additional reforms.

The following information is for internal use only so that we may contact you with any follow-up questions. Information will not be shared without your permission.

Organization

State

Your Name

Phone

Are you a member of your state association of nonprofits?

Yes

Not sure

Find out more about state association membership [1].

Do you have a positive experience to report regarding the compliance efforts of a pass-through entity (state or local government, or another nonprofit) or federal department/agency?

Yes

If yes, please explain

If you have a negative or unresolved issue to report, what type of challenge have you encountered?

Determining whether the Uniform Guidance requirements apply to the written agreement

Not receiving information from pass-through entity about federal funding source

Pressure to waive right to indirect costs

Inconsistent interpretations of requirements

Unnecessary new or duplicative reporting requirements

Pass-through entity unwilling to negotiate indirect cost rate

Other, please specify

If you have a negative or unresolved issue to report, what type of challenge have you encountered? Other, please specify

Describe the problem you‘ve experienced (include, if possible, specific federal funding program, identification of federal funding agency, and the pass-through entity)

Describe any attempts you have made to correct the situation or document the challenge, and any responses/outcomes

Are you aware of any state or local statute(s) or rule(s) affecting the issue are experiencing? Examples could include a state cap on paying indirect/administrative costs and cost allocation rules that are inconsistent with the Uniform Guidance. If so, please describe, and provide citations or links if possible

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