With only six days remaining before the public comment deadline closes for proposed changes to grant requirements in the Uniform Guidance (2 C.F.R. Part 200), the Office of Management and Budget (OMB) has received more than 80,000 comments. Amid this extraordinarily high level of public interest, members of Congress have urged OMB to either revise key provisions of the proposed rule or extend the unusually short 45-day comment period provided in the notice of proposed rulemaking (NPRM).

Published in the Federal Register on May 29, 2026, as “Regulation for Federal Financial Assistance,” 91 FR 32198, the NPRM would:

• Establish a new pre-award review process for grants involving senior political appointees;
• Expand federal agencies’ authority to terminate grants no longer considered to be in “the national interest”;
• Eliminate appeal rights for discretionary grant terminations and temporary funding suspensions;
• Impose new restrictions on certain “allowable” costs including advertising and public relations, publication and printing costs, conferences, memberships, subscriptions, and professional activity expenses; and
• Add new compliance obligations on recipients with respect to cash management and cost reimbursement contracts.

Organizations and individuals still interested in submitting comments can do so no later than July 13, 2026, at this link: https://www.regulations.gov/document/OMB-2026-0034-0001. 

OMB has indicated that it intends to finalize the rule no later than September 1, 2026, with an effective date of October 1, 2026. Given the volume of comments received, the agency faces a significant challenge of reviewing and responding to the issues raised in thousands of comments before September 1, 2026.

As the comment deadline approaches, congressional concern over the proposed rule continues to grow. On July 6, Senator Susan Collins (ME), Chair of the U.S. Senate Committee on Appropriations, sent a letter to OMB, requesting an extension of the comment period and urging the agency to withdraw proposed changes that could significantly impact  “small and rural communities and scientific and biomedical research.” Earlier, in late June, Representatives Jamie Raskin (MD-08), Suzan DelBene (WA-01) and Lori Trahan (MA-03), along with 122 Members of Congress, sent a letter expressing concern that the proposed changes would adversely affect scientific research funded by the National Institutes of Health and at research institutions nationwide. Additional lawmakers have also released statements opposing the proposed rule.

Despite lawmaker concerns, OMB appears committed to its expedited schedule, with Director Russell Vought indicating the agency will not extend the comment deadline. 

Recipients and subrecipients of federal financial assistance should continue to monitor developments closely as this accelerated rulemaking process moves forward.

If your organization has questions about submitting comments on the proposed Part 200 changes or federal grant requirements, please contact Feldesman’s Federal Grants attorneys: Phillip Escoriaza, Mindy Pava, or Ted Waters.