Virtual GMBoK Training | September 1-2, 2026-UG Crosswalk

UG Crosswalk

Pdf Summary

This document is a training crosswalk comparing the current Uniform Guidance at 2 CFR Part 200 with OMB’s May 29, 2026 proposed rule for Federal financial assistance. It emphasizes that the proposed changes are not yet final and may change before issuance.<br /><br />Overall, the NPRM keeps many core Uniform Guidance concepts but introduces significant policy, compliance, and operational changes. Many revisions are technical or conforming, such as terminology updates, reorganization, and clearer cross-references. However, several proposed changes are substantial and may require agencies and recipients to revise policies, systems, training, templates, and monitoring processes if finalized.<br /><br />Major proposed changes include:<br />- Expanded and clarified definitions and applicability rules across the regulation.<br />- New disclosure obligations and stronger conflict-of-interest and mandatory disclosure expectations.<br />- Elimination of fixed amount awards and fixed amount subawards.<br />- More detailed and transparent NOFO, merit review, and risk review requirements.<br />- Stronger restrictions on telecommunications and video surveillance equipment.<br />- New prohibited uses of Federal funds, including DEI/DEIA-related activities, certain gender ideology-related uses, and support for covered foreign collaborations.<br />- Increased emphasis on recipient accountability, internal controls, documentation, and stewardship.<br />- Mandatory E-Verify and Do Not Pay-related payment checks, plus state verification of payment recipients’ eligibility.<br />- Significant cost principle changes, including new prior-approval or unallowability rules for conferences, subscriptions, memberships, and publication costs.<br />- Procurement revisions, including discouraging cost-reimbursable contracts and clarifying Buy America-related requirements.<br />- Audit-related updates that largely preserve the Single Audit framework but strengthen oversight and follow-up expectations.<br />- Broader agency and recipient implementation planning requirements.<br /><br />The document concludes that organizations should begin readiness planning now by reviewing governance, financial management, procurement, subrecipient monitoring, internal controls, cost allowability, and audit preparedness.

Keywords

Uniform Guidance

2 CFR Part 200

OMB proposed rule

Federal financial assistance

compliance changes

internal controls

procurement revisions

cost allowability

Single Audit

readiness planning