The U.S. Department of Housing and Urban Development (HUD) recently published a rule that made numerous changes to grant administration, procurement, and contracting requirements. The rule repealed the requirements found at Part 84 and Part 85 and replaced them with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards found at 2 CFR Part 200. The changes will affect state, local, and Indian tribal governments, as well as nonprofit organizations and public housing agencies that receive federal awards.

The normal 30-day waiting period for implementing a new regulation has been waived, making the rule effective December 26, 2014. This means that federal awards made before December 26, 2014, will continue to be governed by 24 CFR Part 84 and 85. In instances where a federal award before this date provides that the award shall be subject to regulations as amended, then it will be governed by 2 CFR Part 200.

The new standards differ from Part 84 and 85 and will now be government-wide, affecting procurement and contracting for many federal agencies, including HUD. Links to the December 19, 2014, Federal Register and 2 CFR Part 200 are available for your reference.

Ballard Spahr's Housing Group will continue to provide further analysis and updates of this rule.

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This alert is a periodic publication of Ballard Spahr LLP and is intended to notify recipients of new developments in the law. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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