Member Login
Search
 


The HHS 4th Revision:
What It Means for Smaller Organizations
By D’Laun Oubre, MBA
Director of Grants Management Services
Kim Joyce & Associates, LLC

Effective October 1, 2025, the U.S. Department of Health and Human Services (HHS) will officially retire its 45 CFR Part 75 framework. Going forward, HHS will adopt the 2 CFR 200 Uniform Guidance in full, with agency-specific provisions codified under 2 CFR Part 300.

For many organizations, this may look like a simple regulatory update. In reality, the changes bring new requirements that will affect day-to-day operations, financial oversight, and long-term planning. Smaller organizations, in particular, may feel the weight of these revisions, as lean teams and limited infrastructure make it harder to adapt quickly.
At the same time, the shift offers an opportunity to strengthen internal systems and build lasting capacity.

Key Changes

1.  Regulatory Realignment


HHS has now aligned itself fully with the 2 CFR 200 framework, supported by a new set of rules under Part 300. Grantees will need to update internal policies, grant manuals, and related documentation to reflect the new structure. While streamlining this framework is intended to create consistency across agencies, it requires focused administrative work to ensure nothing is overlooked.


2.  Lower Budget Revision Thresholds


The threshold for prior approval of budget revisions has dropped from 25% of total direct costs to 10% of the total approved budget, including cost share. As a result, grantees should expect to seek approvals more often and will need to monitor budgets more closely to avoid delays.


3.  Expanded Civil Rights Certifications


Grantees must now certify compliance with Title IX and other civil rights requirements across all awards, not just those where the language appears in the Notice of Award. This change increases accountability and underscores the importance of integrating civil rights compliance into every program.


4.  Stricter No-Cost Extension Rules


Requests for no-cost extensions must be submitted at least 10 days before the end of the budget period in the final year of performance. Previously treated more flexibly, this deadline is now a firm requirement, and late requests will likely be denied. Careful planning during close-out will be essential to avoid leaving funds unspent.


5.  Termination for Convenience


HHS now reserves the right to terminate awards for its own convenience, with no appeal available to grantees. This provision creates real financial risk, particularly for smaller organizations with limited reserves or few funding sources. Building contingency plans will be critical.

Preparing for the Transition

Adapting to these changes will require preparation, but there are practical steps smaller organizations can take:

  • Review policies and practices. Conduct a gap analysis to identify where current systems do not meet the new requirements.
  • Update internal documents. Manuals, standard operating procedures, and templates should reflect new rules and thresholds.
  • Invest in training. Staff and board members should understand both the changes and their roles in maintaining compliance.
  • Strengthen documentation. Consistent, well-organized records of financial activity, performance data, and civil rights compliance will help ensure readiness for audits.
  • Communicate with funders. Proactive dialogue with funding agencies can clarify expectations and provide room for flexibility during the transition.

Looking Ahead

The new guidance is more than a compliance exercise. For smaller organizations, it is an opportunity to create stronger, more resilient systems that will support growth and stability over time. By approaching the revisions with intention and preparation, organizations can not only remain in compliance but also position themselves to thrive in a funding environment where accountability and competition continue to grow.

Those who invest in building strong compliance infrastructure now will be better equipped to deliver programs effectively, serve their communities with confidence, and sustain their work well into the future.


D’Laun Oubre, MBA is a seasoned grants management leader with nearly two decades of experience in accounting, post-award compliance, and federal funding oversight. As Director of Grants Management Services at Kim Joyce & Associates, she has stewarded $30 million+ in funding while mentoring teams, embedding internal controls, and shaping best practices in federal grants compliance.

She’s an active member of the National Grants Management Association and a trusted voice in the field of federal grants compliance.