The revised 2 CFR Part 200 regulations, effective October 1, 2024, and the Trump administration’s Department of Government Efficiency (DOGE) initiative have made federal grant program evaluation crucial. An evaluation is now essential for demonstrating accountability and measurable outcomes in relation to federal grants.
This first article of a three-part series on program evaluation for federal grantees will explore the evolving regulatory environment of federal grant management. This installment outlines the new regulatory framework, the role of DOGE, and practical steps to help grantees align with federal priorities.
The Revised 2 CFR Part 200: A New Era for Federal Grants
The Office of Management and Budget (OMB) introduced extensive revisions to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200) in 2024, marking the most significant update to federal grants guidance in years. These changes emphasize accountability, transparency, and measurable outcomes, aligning with the government’s priority of efficient governance. A few key modifications include increasing the Single Audit threshold from $750,000 to $1 million, simplifying definitions for equipment and supplies, and enhancing performance measurement.
Under 2 CFR 200.301, federal agencies are now urged to measure recipient performance to enhance program objectives, share lessons learned, and promote best practices across the grants ecosystem. This shift moves evaluation beyond mere compliance, now requiring recipients to demonstrate programmatic effectiveness through rigorous methods: for example, using well-designed trials or systematic methods for data collection, analyzing, and using information to demonstrate the effectiveness of the programs. These changes indicate a clear mandate: grantees must prioritize measurable outcomes to justify grant funds.
Outlined below are a federal agency’s responsibilities under 2 CFR 200.301 Performance Measurement:
Specify indicators, targets, baseline data, or data collections that the recipient is responsible for measuring and reporting
Requirements for measuring performance align with the federal agency’s strategic goals, strategic objectives, or performance goals relevant to a program (see OMB Circular A-11, Preparation, Submission, and Execution of the Budget Part 6)
Specify in the federal award any requirements for the recipients' participation in federally funded evaluations
There is also added emphasis on monitoring and reporting program performance under 2 CFR 200.329. The responsibilities of recipients and subrecipients under this requirement include:
The Role of the Department of Government Efficiency (DOGE)
Launched this year, the Trump administration’s DOGE initiative underscores a commitment to transforming federal spending on contracts, grants, and loans. DOGE aims to provide transparency in government spending and hold federal employees accountable to the public. Issued in 2025, Executive Order 14222 targets discretionary spending, including grants, by curbing nonessential expenses such as conference travel, helping enhance program effectiveness. Some important actions aimed at improving performance and accountability suggested under this executive order include:
- Agencies must build a technological system to record every payment under covered contracts and grants.
- Each payment must be accompanied by a brief, written justification from the approving employee.
- To the extent permitted by law, these justifications are to be posted publicly, reinforcing transparency and public oversight.
- Each agency’s DOGE Team Lead must submit monthly reports to the agency administrator, including payment justifications and travel approvals.
- Agencies must review and potentially terminate or renegotiate existing contracts and grants to eliminate waste and improve efficiency.
- A 30-day freeze was placed on agency credit cards (with exceptions), curbing unnecessary expenditures.
This efficiency-driven approach extends to accountability measurement. Such actions demonstrate how performance measurement is being leveraged to align federal spending with high-impact priorities, setting a precedent for grantees to follow.
Practical Tips for Grant Recipients
As federal grantees, the below steps can help your organization plan for program evaluation and data collection while maintaining compliance with federal guidelines.
- Budgeting for Allowable Costs: Under Subpart E – Cost Principles, specifically §2 CFR 200.413 and §2 CFR 200.455c, grantees can now charge costs related to data collection and program evaluation as direct or indirect costs, provided they are related to the federal grant award. These include:
- Data Activities: Gathering, managing, publishing, and using data, such as integrated data systems.
- Evaluation Activities: Evidence reviews, evaluation planning, feasibility assessments, conducting evaluations, sharing results, and other personnel/materials costs for effective evidence and evaluation use in program design, administration, or improvement.
When preparing grant budgets, grantees can plan to include these costs and justify them clearly in proposals.
- Developing and Implementing Comprehensive Evaluation Plans: Under 2 CFR 200.202, grantees must now establish robust program planning and design processes with clear objectives and performance metrics aligned with federal award goals. Grantees must define specific, measurable outcomes to demonstrate program impact, as required by 2 CFR 200.301. The revised guidance also emphasizes the role of program evaluation in meeting compliance and improving program outcomes. It includes the following key steps:
- Create a clear evaluation plan that aligns with your grant’s objectives.
- Document how these evaluations support the grant’s performance goals, confirming you can demonstrate compliance during audits.
- Focusing on Proper Data Management and Reporting: Section 2 CFR 200.334 mandates that federal award-related information, including data for program evaluation, be collected, transmitted, and stored in open and machine-readable formats. Grantees are responsible for monitoring their activities to meet performance expectations, as outlined in §200.329. This includes relating financial data to performance accomplishments and providing cost information to demonstrate cost-effective practices.
- Plan to use standardized, federal agency-approved information collections for reporting program performance.
- Confirm your data systems can generate reports in machine-readable formats, such as CSV or XML, to meet federal requirements.
- Align the due dates of performance and financial reports to streamline compliance, with reporting frequency typically no less than annually and no more than quarterly, though more frequent reporting may be required for significant program outcomes (§2 CFR 200.328).
Conclusion
Federal grantees should act now to align with 2025 standards. Review the revised 2 CFR Part 200 and DOGE guidelines at federalregister.gov and whitehouse.gov. Develop evaluation plans with measurable outcomes and engage in federal performance networks to adopt best practices. By prioritizing accountability, you can not only maintain compliance but also deliver meaningful results. Stay tuned for Part 2, which will assist you in designing effective evaluation systems.
If you have any questions or need assistance, please reach out to a professional at Forvis Mazars.