Over the past few years, the federal government, through the U.S. Office of Management and Budget (OMB), has significantly rewritten its guidance concerning grants and cooperative agreements (referred to as the Uniform Guidance). We have written extensively on these changes, which demonstrate substantial movement toward a more formal, contract-like approach. In light of those changes, the U.S. Department of Defense Grant and Agreement Regulations (DoDGARs) required updating. The U.S. Department of Defense (DoD) established interim implementation of OMB’s guidance in December 2014. On November 7, 2016, the DoD took further steps to implement the OMB guidance. The six proposed rules seek to establish eleven new DoDGARs parts and make conforming changes to existing DoDGARs parts. The six proposed rules for comment are as follows:
- Revised Interim Implementation of Governmentwide Guidance for Grants and Cooperative Agreements;
- Format for DoD Grant and Cooperative Agreement Awards;
- Administrative Requirements Terms and Conditions for Cost-Type Awards to Nonprofit and Governmental Entities;
- National Policy Requirements: General Award Terms and Conditions;
- Definitions for DoD Grant and Agreement Regulations in Subchapters A Through F; and
- DoD Grant and Agreement Regulations.
Comments on each of these are due February 6, 2017.