Yesterday, the Office of Management and Budget (OMB) issued the updates to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance") that grantees have been anticipating. They are available via the Federal Register here, and have been issued as a proposed rule with a 45-day comment period.
As expected, the updates appear to be substantial. Per OMB's summary describing the updates, the proposed revisions focus on "ensuring that American tax dollars are not wasted or misused, activities performed under Federal awards are consistent with law and policy, and recipients are held accountable when they fail to meet relevant standards" and are designed to ensure "that unlawful discrimination is no longer permitted." These statements are consistent with efforts in 2025 and early 2026 to modify grant-related requirements related to diversity, equity, and inclusion activities and recent widely publicized efforts to aggressively target improper payments in federal programs.
Venable's Government Contracts and Grants Practice attorneys are carefully reviewing the changes and will issue analysis in the coming days. For access to Venable client alerts on grant law, please register at Venable's Government Grants subscription center.
For questions about the proposed updates to the Uniform Guidance or other federal grant matters, please feel free to contact Christopher Griesedieck, Dismas Locaria, and Scott Sheffler.