GRF Responds to Proposed Uniform Grants Regulation Changes
On May 29, 2026, the Office of Management and Budget (OMB) issued proposed revisions to the federal grant rules currently known as the Uniform Guidance under 2 CFR Part 200. The proposal reflects a shift toward greater oversight and control of federal funds, including a move from the current “Uniform Guidance” framework to a broader Uniform Grants Regulation concept. OMB released the proposed revisions in a lengthy document and invited public comment through Monday, July 13. More than 341,000 comments were submitted.
GRF submitted comments on key areas of the proposed revisions to advocate on behalf of our clients that receive federal funds. These areas included:
- Enhanced definitions and clearer explanations of terminology used in the proposed revisions.
- Modification of the proposed restrictions on allowable costs under the proposed cost principles.
- Reconsideration of the proposed implementation timeline and effective date.
Definitions and Clarifications
Several areas of significant interest in the proposed revisions are not clearly defined. GRF emphasized that clearer definitions, practical examples, and additional guidance are needed to support consistent implementation by federal fund recipients and effective review by auditors or other independent third parties. Without this clarity, organizations may inadvertently misapply the requirements or they may be applied inconsistently across federally funded programs.
Cost Principles
The proposed revisions would add new restrictions on allowable costs, significantly limiting what federal agencies may fund. In its comments, GRF emphasized that costs such as public relations and advertising, conference attendance, publications, and memberships and subscriptions can be essential to an organization’s mission. Based on our experience with the nonprofit community, these expenses are not merely overhead; they are often carefully planned investments that help organizations expand their reach, strengthen their programs, and advance their impact.
Implementation and Effective Date Timing
The proposed effective date for these revisions is October 1, 2026. In its comments, GRF noted that the scope of the proposed changes is sweeping and would significantly affect the entire ecosystem of federally funded organizations, including auditors. Impacted organizations will need sufficient time to understand the final revisions, train staff, update policies and procedures, modify software and systems, and implement related operational changes. Moving forward too quickly could create confusion and unnecessary burden for both OMB and the organizations responsible for complying with the revised requirements.
GRF will continue monitoring OMB’s proposed revisions and advocating for clients that rely on federal funding.