Proposed Uniform Guidance Changes: What Grant-Funded Organizations Need to Know
On May 29, 2026, OMB published 412 pages of proposed changes to 2 CFR 200 — affecting new federal awards starting FY 2027. We read all of it so you don't have to. Get the free plain-language guide and join our free two-part Lunch & Learn.
Part 1: Tuesday, July 7, 2026 · 12:00 PM ET
Part 2: Tuesday, July 21, 2026 · 12:00 PM ET
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The Proposed Changes in 90 Seconds
What's being proposed, when it would take effect, and what to do about it right now
What's Being Proposed
The biggest rewrite of federal grant rules in a decade. Here are the headline changes — every one is covered in depth in the guide and the sessions.
Binding Rules for Every Agency
The Uniform Guidance would be renamed the Uniform Grants Regulation (UGR) and become binding OMB regulation — one set of rules for all federal agencies, no agency-specific versions.
Fixed-Amount Awards Mostly Eliminated
Lump-sum funding would largely be prohibited. Agencies and pass-through entities would shift to cost-reimbursable models unless Congress specifically authorizes otherwise.
Political Review Before Awards
Senior political appointees would review discretionary grant proposals before award — checking alignment with federal law, agency priorities, and presidential priorities.
Expanded Applicant Risk Review
Agencies would look deeper at financial stability, past issues, affiliations, and prior performance based on outcomes — not just compliance.
E-Verify, Do Not Pay & Justified Drawdowns
E-Verify would extend to all grant recipients and subrecipients. Agencies must check the Do Not Pay system before releasing funds, and every drawdown request would need a written justification.
Heavier Subrecipient Monitoring
Pass-through entities would report subawards to SAM.gov within one month and monitor subrecipients for actions causing "significant reputational harm."
Broader Termination Authority
Agencies could terminate awards at any time if they decide the award no longer aligns with agency priorities — with only a "brief summary" of the reason and limited appeals.
New Spending Restrictions
New limits on advertising, conferences, lobbying, and publications — plus prohibitions tied to recent executive orders on DEI, event services, and foreign collaborations.
What's NOT Changing
- Indirect cost rates: the 15% de minimis rate remains unchanged
- Tribal sovereignty: tribal nations continue to be treated like states for procurement
Nothing Has Legally Changed Yet
These are proposed revisions. The 2024 Uniform Guidance remains in force until a final rule is issued. The public comment period closes July 13, 2026, and the proposed effective date of October 1, 2026 is not final — now less than 18 weeks away, so preparing early pays off.
A Two-Part Lunch & Learn
Grab your lunch or coffee and join fellow grant professionals. Informative, practical, and useful at every career stage.
Overview of the Proposed Changes
- Stronger federal oversight and enforcement
- Increased political and agency control over awards
- National policy and security conditions attached to grants
- DEI, event-services, and viewpoint requirements
- The broader direction of federal grant reform
Preparing for the Proposed Changes
- Operational and compliance implications for your organization
- Allowable costs under the proposed rules
- Internal controls in a framework-flexible world
- Getting ready for FY 2027
Jacqui May, Ph.D.
Jacqui hosts every session live — so you're not watching a recorded webinar, you're in the room. Bring your toughest questions and get straight, plain-English answers, alongside a friendly community of grant and procurement pros working through these changes together.
The Grant Management Lunch & Learn series is offered by ProcurementExpress as a way of giving back — adding value to the work you do and building an engaged community of grants and procurement professionals.
We Read All 412 Pages So You Don't Have To
The guide distills OMB's entire proposal into plain language your whole team can use — finance, program, and leadership alike.
- Every proposed change at a glance — one summary table
- Plain-language detail on oversight, payments, procurement, and terminations
- What's NOT changing (indirect rates, tribal sovereignty)
- Key dates: comment deadline, proposed effective date, FY 2027
- A sensible next-steps checklist for your organization
- What to monitor as the proposal moves toward a final rule
Proposed Changes to the Uniform Guidance
What Grant-Funded Organizations Need to Know About OMB's Proposed Rewrite of 2 CFR 200
What to Monitor Right Now
The proposal isn't final — but these six areas deserve your attention today
Award Terms
Look for new language in NOFOs and grant agreements about foreign entities, DEI restrictions, event rules, or national-security conditions.
Payment Requests
Expect tighter rules on drawdowns. Staff may need to provide a short justification for each request.
Subrecipient Risk
More attention on foreign affiliations, cybersecurity, and internal controls across your subaward portfolio.
Cost Allowability
Some costs — advertising, conferences, publications — may face new limits.
Termination Language
Agencies may use "termination for convenience" more often. Read new agreements closely.
Official Sources
Keep an eye on Grants.gov, federal agency websites, and the CFR as the proposal moves toward a final rule.
Join a Community of Grant Professionals
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Managing Uniform Guidance Is About to Get Tougher
Which makes now the perfect time to make sure your tools and workflows can keep pace — so you stay audit-ready and always covered. Get the guide and join us Tuesday, July 7 at 12:00 PM ET for Part 1.
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