2026 Proposed Changes to Uniform Guidance

On May 29, 2026, the federal Office of Management and Budget (OMB) published a proposed rule in the Federal Register that would substantially revise 2 C.F.R. Part 200, commonly referred to as the “Uniform Guidance”, which applies to federal grants, cooperative agreements and other types of federal assistance funding.

If finalized, the proposed rule would significantly impact federal awards, including codifying Executive Orders.  It would change Uniform Guidance to Uniform Regulations, having the practical impact of adoption across all agencies, rather than each agency setting forth in its own agency regulations.  These areas will be highly impacted:

  • How To Apply for Funding
  • Who Applicants May Work With When Seeking Federal Funding
  • How Award Decisions are Made
  • Allowable Costs
  • Type of Award and Award Payment
  • Prohibitions
  • Expanded Rights the Federal Government Has in Setting Conditions, Modifying or Terminating Awards
  • Remedies and Procedural Rights

Because these changes have significant implications for federally funded research, the university will be submitting comments in response to the proposal. As noted in the Provost’s newsletter, we are seeking your input on the University’s overall response. Please use the University’s “Uniform Guidance – Proposed Changes” intake form to provide your comments to University leadership to support the University’s official response to OMB. You will need a UW NetID to access the intake form. Please respond by July 1, 2026.

“Uniform Guidance – Proposed Changes” intake form

Guidance for submitting an individual response

As a member of the public, you may also comment directly to OMB; however, OMB will only accept one institutional response, so it is important that if faculty, staff, or students wish to submit an individual response, that they do not use UW letterhead or imply that they are commenting on behalf of the institution. The comments will become public record, so we encourage people not to provide names or institutions to avoid unwanted attention via social media or other channels.  (Email addresses should not be posted publicly.)

Sample language for an individual comment:

  1. Identify yourself (for frame of reference): “I am a faculty member at a public R1 university whose research on [topic] has been supported by [agency] for [X] years.” OR “I am a graduate student in [field] at a public flagship university who receives NIH funding.” OR “I am a research scientist at a large public university who has been conducting NIH-funded research for [X] years on [topic].
  2. Identify specific provision(s) that concern you by section number and explain what they would do. Selected sections that may impact research are listed below.
  3. Explain how these changes would harm you/your lab/your institution/your field in plain non-technical language. Be personal – e.g. grant termination in my 3rd year of graduate school would mean I would not have funding to finish my degree.
  4. Closing: State clearly what you want OMB to do. This can be as simple as: “I urge OMB to withdraw this provision” or “I urge OMB not to finalize this rule.”

Selected Sections

  • §200.205 — Political appointee review of grants
  • §200.340 — Grant termination
  • §200.432 — Conference attendance pre-approval
  • §200.454 — Journal subscriptions (now unallowable)
  • §200.461 — Publication costs (now unallowable)
  • §200.300 — DEI and gender ideology prohibitions
  • §200.218 — Disparate-impact research banned
  • §200.220 — Foreign collaboration prohibition
  • §200.202 — Programs must align with administration priorities
  • §200.204 — Grant competitions can be exempted from public notice

Sections organized by topics

  • How to apply for funding: §200.201, §200.202, §200.204, §200.206
  • Who applicants may work with: §200.202, §200.220
  • How award decisions are made: §200.202(g), §200.204(a), §200.205(b), §200.206(b)
  • Allowable costs: §200.432, §200.454, §200.461, §200.477
  • Type of award & award payment: §200.201, §200.305
  • Prohibitions: §200.218, §200.219, §200.300(b), §200.450
  • Expanded Rights for the Federal Government: §200.208, §200.340
  • Remedies and Procedural Rights: §200.339(b), §200.340-343

Resources: