Compliance Conversations | Proposed Uniform Guidance Updates: Key Insights and Next Steps-Webinar Slides

Webinar Slides

Pdf Summary

This presentation summarized OMB’s proposed 2026 updates to the Uniform Guidance (2 CFR Part 200), which are intended to take effect October 1, 2026 for new federal awards in FY 2027 and beyond. A major theme is that Part 200 would be treated more clearly as binding federal regulation rather than subregulatory guidance.<br /><br />Key proposed changes include:<br />- Eliminating fixed amount subawards unless specifically authorized by statute.<br />- Expanding merit review and risk review, including review by senior political appointees and broader scrutiny of applicants’ financial capacity, practices, affiliations, and prior performance.<br />- Adding or strengthening restrictions related to disparate-impact theories, discriminatory event services, foreign collaborations, DEI-related activities, gender ideology, and certain child transition-related services.<br />- Increasing internal controls and compliance requirements, including E-Verify for grant-funded employees and contractors, stricter cash management, and more detailed drawdown justifications.<br />- Tightening procurement rules, discouraging cost-reimbursement contracts, revising small business considerations, and requiring stronger documentation.<br />- Expanding subrecipient monitoring and classification rules, especially for transfers to related entities, and allowing termination based on reputational harm.<br />- Broadening discretionary termination authority so agencies can end awards they view as inconsistent with current program goals or priorities, with limited appeal rights.<br /><br />The rule also proposes cost allowability changes, including restrictions on advertising, conferences, lobbying/advocacy, memberships and subscriptions, and publication costs, while adding abortion as a distinct unallowable item of cost. <br /><br />A few positive notes were highlighted: multi-year awards are encouraged, the 30-day minimum posting period for funding opportunities remains, the 15% de minimis indirect cost rate stays unchanged, and tribal sovereignty is still recognized.

Keywords

OMB 2026 Uniform Guidance

2 CFR Part 200

federal grant regulations

merit review

risk review

subrecipient monitoring

procurement rules

cost allowability

indirect cost rate

grant compliance