On Thursday, May 28, 2026, the Office of Management and Budget (OMB) announced significant pending changes to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), codified at 2 C.F.R. Part 200, and agency-specific adoptions and deviations as appropriate. The formal announcement is scheduled to be published in the Federal Register on May 29, 2026.

Comments on the proposed rule will be due to OMB within 45 days after the notice is published in the Federal Register.

Proposed Updates to Uniform Guidance

The announcement explains revisions will:

• Improve transparency, accountability, and oversight;
• Clarify status of Part 200 as OMB regulation, not guidance; and
• Reduce recipient burden.

Selected proposed changes include:

• Requiring approval by a senior appointee before an agency may issue a notice of award (§ 200.205(b))
• Extending the “Huawei Ban” to drones (§ 200.216)
• Adding prohibitions on:
  • Using grant funds to support collaborations with covered foreign entities and covered foreign countries (§ 200.220)
  • DEI, DEIA, and gender ideology programs, as well as funding to support “transition” (Gender Affirming Care) for minors under age 19 (§ 200.300(b))
• Expanding the DHS E-Verify system citizenship status checks in FAR-funded contracts to grant-funded employees and contractors, but not to “activities unrelated to Federal awards” (§ 200.303(f))
• Requiring recipients (other than States) and subrecipients to submit brief drawdown payment justification to their funding agency and pass-through entity, respectively (§ 200.305(c))
• Eliminating fixed amount subawards (§ 200.333)
• Adding discretionary (“for convenience”) authority for agency or PTE to terminate grants or subawards, respectively, except when prohibited by statute (§ 200.340(a))
• New Subpart E item (§ 200.477): costs associated with elective abortions are unallowable

Under the proposed rule, the basic legal framework and organization of the Uniform Guidance, including section numbering, will largely remain intact. Of note, OMB is not proposing updates to indirect cost rate negotiations, but may consider this topic in future rulemaking. Overall, the new provisions codify various directives in recent executive orders relating to DEI, gender affirming care, gender ideology, and grant terminations, among others.

Stay current on the latest Uniform Guidance Changes by joining Feldesman’s upcoming webinar, OMB Proposed Uniform Guidance Changes, on June 8, 2026, at 1 p.m. ET.

Feldesman’s federal grants attorneys will continue monitoring developments related to the proposed Uniform Guidance changes. If you have any questions, please contact Phillip Escoriaza, Adam Oppenheim, Mindy Pava, or Ted Waters.