Resources on OMB’s Proposed Changes to Federal Funding

On May 29, the Office for Management and Budget (OMB) released a proposed rule to update the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards or Uniform Guidance (found at 2 C.F.R.  § 200). This proposed rule would establish baseline requirements for federal programs including research grants. These requirements will govern how awards are issued, approved, managed, monitored, or canceled. Comments are due by Monday, July 13 at 11:59 PM EDT. OMB indicated it would like to issue a final rule that would put the proposal into effect at the beginning of the next fiscal year on October 1, 2026. APLU sent a letter late last week asking for a 45-day extension of the comment period beyond the July 13 comment deadline.

APLU will work with member institutions to continue to assess the proposal and provide comments to OMB in response. We encourage APLU members to also plan to send their own individual comments.

APLU has summarized some major issues that could impact member institutions. Additionally, APLU, the Association of American Universities, and COGR have jointly developed a high-level brief highlighting five key issues for institutions to begin considering as they evaluate the White House Office of Management and Budget’s (OMB)’s proposed revisions to Uniform Guidance. While not intended to be an exhaustive analysis, or as detailed as APLU’s Key Issues document, it outlines several areas that may have significant implications for the administration, oversight, and conduct of federally funded research. This is meant to help focus constructive campus discussions. This brief focuses on:

• Expanded agency discretion in funding decisions
• Expanded agency abilities to suspend and terminate grants
• Changes in allowable and unallowable costs on grants
• Restrictions on international collaboration and expanded reporting and monitoring of subrecipients
• Elimination of fixed amount awards and subaward.

An additional resource is a new white paper from the law firm Ropes & Gray, which APLU is sharing for informational purposes.