Legislative Services

The Office of Management and Budget (OMB) has proposed a rewrite of 2 CFR Part 200, the Uniform Guidance governing how federal grants are awarded, administered and monitored. The rules apply to most federal funding that counties receive, including public safety, transportation, housing, public health and emergency management. The public comment period ends July 13.

What's proposed

• New authority for federal agencies to terminate grant awards mid-program.
• Additional pre-award review requirements.
• Expanded sub-recipient monitoring obligations for pass-through entities.
• A shift of portions of the Uniform Guidance from policy guidance to binding regulation.

How to comment

• Have your county attorney review the proposed rule, particularly the provisions listed above.
• Submit comments at regulations.gov under docket OMB-2026-0034.
• The National Association of Counties offers a template comment letter counties can customize.
• Comments are due July 13.

Resources

NACo has published an analysis, opened a resource hub, and provided a template comment letter and filing instructions. NACo is also hosting listening sessions from 3 to 4 p.m. CT, 2 to 3 p.m. MT on June 30, July 2 and July 7 to gather county input. (Join meetings here.)

Please feel free to contact TAC's William Chapman with any questions.