Resource | Crosswalk of Current Uniform Guidance and 2026 Proposed Regulation for Federal Financial Assistance-Crosswalk of Current Uniform Guidance and 2026 Proposed Regulation for Federal Financial Assistance

Crosswalk of Current Uniform Guidance and 2026 Proposed Regulation for Federal Financial Assistance

Pdf Summary

The document is a crosswalk comparing the current Uniform Guidance (2 CFR Part 200) with OMB’s May 29, 2026 proposed regulation for federal financial assistance. It emphasizes that the proposal is not yet final and notes implementation was delayed until Dec. 11, 2026.<br /><br />Overall, the proposed rule keeps the basic structure of Part 200 but makes many clarifying, conforming, and operational changes. Some revisions are technical, but others are major and could require significant policy, training, system, and documentation updates if finalized.<br /><br />Key proposed changes include:<br />- Updated terminology throughout, replacing “guidance” with “regulation” and aligning definitions, cross-references, and agency terms.<br />- Stronger applicability, exception, conflict-of-interest, and mandatory disclosure provisions, including disclosure of recent federal employment in some situations.<br />- New or tightened pre-award requirements, especially for NOFOs, merit review, risk review, and award conditions.<br />- Elimination of fixed amount awards and fixed amount subawards.<br />- Expanded procurement and screening expectations, including restrictions tied to telecommunications, surveillance, IT, and related products.<br />- New prohibited uses of federal funds, including DEI/DEIA-related restrictions, certain gender ideology-related uses, and support for covered foreign collaborations.<br />- More prescriptive recipient responsibilities, internal controls, E-Verify/Do Not Pay checks, and payment eligibility verification for states.<br />- Major cost principle changes, including more prior approvals and disallowances for some costs such as conferences, periodicals/subscriptions, memberships, publication costs, and elective abortions.<br />- Stronger audit and oversight language while retaining the Single Audit framework, though with some possible narrowing of non-statutory audit authority.<br /><br />The document closes with implementation guidance for agencies and recipients, stressing governance, policy review, training, procurement, subrecipient monitoring, internal controls, and audit readiness as essential for compliance.

Keywords

Uniform Guidance

2 CFR Part 200

OMB proposed rule

federal financial assistance

pre-award requirements

procurement restrictions

cost principles

Single Audit

internal controls

implementation guidance