Five Things To Close Out Before November Turns Into Deadline Season

October 1 came and went. The federal fiscal year restarted under the same Uniform Guidance you have been operating under all year, not the rewritten version OMB proposed back in May. That is not a reason to relax. It is a head start, and most organizations will waste it.

The Quiet Window Closes Fast

The continuing resolution signed September 2 blocks OMB from finalizing its proposed overhaul through December 11 at the earliest. That is roughly two months of runway nobody was expecting. Two months is enough time to fix real gaps if you spend it on purpose. It is not enough time if you spend it assuming the topic is closed.

Check Your E Verify And SAM.gov Status Now

The proposed rule would require E Verify enrollment and SAM.gov subaward reporting for awards of $30,000 or more. Whether or not the final version keeps this exact threshold, both of these are checks you can complete this week at no cost. If your organization has never confirmed its E Verify status, that gap is easier to close in October than to explain in December.

Revisit Anything Tagged Advertising Or Membership Spending

The proposed changes include new restrictions and prior approval requirements around advertising, publications, conference attendance, and memberships charged to federal awards. Pull your chart of accounts and look at how these categories are currently coded. If the answer is loosely, that is worth fixing regardless of what happens to the rule.

Pull Your Award List And Flag What Renews After December 11

Every award that renews, amends, or gets issued after that date is a candidate for whatever final rule eventually lands. You cannot control the timeline. You can control whether you know your own exposure before it matters.

Put A Date On The Calendar, Not A Someday

We see this pattern constantly. An organization knows it should review its award list or check a compliance status, agrees it matters, and then never assigns it a day. Pick one afternoon this month. Put these four checks on it. That is the entire difference between organizations that handle deadline season calmly and organizations that scramble.

None of this requires waiting for a final rule. It requires using the two months you were just given.

If you want a second set of eyes on your award list before November arrives, a free back office assessment is a good place to start. Reply and tell us where you want to look first.