Late last week, the U.S. Department of Health and Human Services (HHS) posted without any fanfare the promised revision to the HHS Grants Policy Statement (GPS), effective October 1, 2025.  This updated version of the GPS conforms to the movement of all HHS grants from the old 45 C.F.R. Part 75 (the HHS version of the Uniform Guidance) to full Uniform Guidance treatment (found at 2 C.F.R. Part 200).  In addition to changing all the citations to Part 200 and a new numbering system, the new HHS GPS adds several substantive updates, including:

• Civil Rights Assurances (2.5.4.3). The last version, posted on July 24, 2025, greatly streamlined the requirements.  The new version adds mandatory certification language tied to, among other provisions, Title IX of the Education Amendments of 1972, language already appearing in certain client awards.
• Significant Budget Changes (3.1.2.2). Prior approval is now required for cumulative budget revisions “expected to be more than 10% of the total budget amount approved by the agency, including cost share,” replacing the prior 25% threshold of total approved direct costs.
• No-Cost Extensions (3.1.4.1). Grantees will be required to request no-cost extensions at least 10 days “prior to the end of the budget period in the last year of the period of performance.”
• Lease Improvements (3.4.9).  Added in last year’s changes, which finally makes “official” the longstanding practice of requiring a landlord letter of consent.
• Termination for Convenience (3.6.4). Explicitly grants HHS the right to terminate awards for its own convenience, with no appeal rights available.

For updates on the HHS Grants Policy Statement, please join Feldesman’s webinar, New HHS Grants Policy Statement: What Grantees Need to Know, on  September 29, 2025 at 1 p.m. ET.

If you have specific questions, please contact Feldesman Managing Partner Ted Waters at ewaters@feldesman.com.