Congress has delayed the Oct. 1 implementation date to Dec. 11, but some agencies are moving ahead on their own.
The U.S. Office of Management and Budget (OMB)’s proposed changes to the federal grantmaking guidelines are on hold for now. In their FY2027 Continuing Resolution, which continues federal funding at current levels, Congress included a provision to delay any changes to the OMB’s Uniform Guidance. This pushes any updates until at least December 11, at which point congress will need to approve a FY2027 budget or agree to another continuing resolution. This is good news for nonprofits preparing to accommodate those changes.
However, key agencies – including the Department of Education, the National Science Foundation, the Department of Justice, and more – have begun to voluntarily amend their own grantmaking guidelines to reflect the OMB’s proposed changes. This alignment of their policies to reflect intended changes to the Uniform Guidance may indicate that the proposed rules are expected to go into effect when the continuing resolution expires. Agency adoption could also indicate the Trump administration’s commitment to changing the federal grantmaking process.
Is your nonprofit prepared to comply with changing federal guidelines?
When the OMB released their proposed FY 2027 rule changes at the end of May, it was expected that the final rules would be released in September, ahead of an October 1 implementation date. The agency received a tremendous amount of feedback – nearly 500,000 comments – raising concerns about the proposed rules. Comments focused largely on the ambiguity and lack of definitions around decision making, the replacement of key decision-makers with political appointees, and the instability created by allowing agencies to disrupt contacts mid-term. A comprehensive outline of our key concerns for nonprofits is available here.
The OMB’s Uniform Guidance is a “government-wide framework for grants management.” This acts as an authoritative set of rules and requirements for federal awards across government agencies. While the OMB does not have the authority to change grantmaking rules within a given agency, adherence to their guidelines is required. All disbursed federal funds flow through the OMB, including grants and contracts with nonprofits, state and local governments, and private contractors. Nonprofits receiving indirect federal funding – through block grants, for example – or working with corporate foundations who hold federal contracts would also be subjected to revised guidelines.
- Learn more here:
The Uniform Guidance and UGR Compared (congress.gov)
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