Uniform Guidance Proposed Changes: Speak Now or Forever….

If you touch federal grants in any way—direct recipient, subrecipient, or pass-through entity—I need you to put down your coffee, because OMB just proposed a major overhaul of 2 CFR Part 200, the Uniform Guidance. This is the rulebook governing how we apply for, manage, and close out federal awards, and the proposed changes would take effect October 1, 2026, if finalized.

Amanda and I dig into this in much more detail on the latest episode of the Fundraising HayDay podcast, but here are a few highlights so you have time to act before the comment period closes.

More paperwork, less help. Grantees would need written justifications for every payment request, would have to run federally funded staff through E-Verify, and would face expanded Buy America requirements on all awards—with zero additional funding to manage any of it.

Funding gets shakier. Agencies could terminate awards mid-stream if they no longer align with “Executive Branch policies” not the policies in place when you got the grant, but whatever exists when they decide to pull funding, often with no appeal process. From the What a Surprise Department: The proposed changes do not offer any definitions of Executive Branch Policies because they refer to things that wouldn’t have yet occurred at the time of writing the grant or receiving and executing the grant agreement.

Political appointees get a say. A new “pre-issuance review” would let political appointees screen out applications before they reach merit review, and applicants wouldn’t even be notified. What could possibly go wrong? Spoiler: Everything!

The good news: this isn’t final yet, and your voice can shape it. Public comments are due by July 13, 2026, and substantive, personal comments carry real weight—way more than form letters.

A few quick tips for writing yours:

• Introduce yourself and your organization, then get specific. Reference actual programs, dollar amounts, or staff time that would be affected.
• Cite the docket number, OMB-2026-0034, so your comment is properly linked.
• Keep it respectful, skip personal contact info (everything submitted is public), and don’t wait until the last minute.

Submit your comment HERE.

This one’s worth the twenty minutes it takes to write. Go give them a piece of your mind—professionally, of course.