Executive Summary
When the Office of Management and Budget (OMB) issued its proposed revisions to the Uniform Guidance (2 CFR Part 200), the federal grants community immediately began analyzing what could become the most significant update to federal financial assistance requirements since the Uniform Guidance was introduced in 2013.
In our earlier BDO Insights article, we examined the proposal’s key provisions and discussed their potential implications for organizations receiving or administering federal awards.
Several weeks later, the discussion has evolved.
The proposal remains open for public comment through July 13, 2026, and organizations across the country are now evaluating not only what the proposed changes mean but also how they may affect program delivery, administrative burden, governance, internal controls, compliance, and audit responsibilities.
More than 40,000 public comments have already been submitted as of June 30, 2026, reflecting the broad interest these proposed changes have generated. While that level of participation is significant, many organizations have yet to share their own operational experiences and perspectives. Those voices remain critically important as OMB considers the final regulation.
This article provides an update on where the proposal stands, highlights themes emerging from the federal grants community, and discusses why organizations should consider participating in the rulemaking process before the comment period closes.
Where Things Stand
The proposed revisions remain in the public comment phase. Once the comment period closes on July 13, 2026, OMB will review the comments received, evaluate recommendations, and determine whether revisions should be made before issuing a final rule.
This process is more than a procedural requirement. It is one of the primary ways federal agencies obtain practical insight from the organizations responsible for implementing federal programs.
Many of the refinements made to previous versions of the Uniform Guidance resulted from thoughtful stakeholder feedback identifying operational challenges, unintended consequences, or opportunities to improve clarity.
For that reason, organizations should view the current comment period as an opportunity to contribute to the development of a stronger and more effective regulation.
What We’re Hearing
As BDO has spoken with nonprofit organizations, state and local governments, institutions of higher education, healthcare organizations, pass-through entities, and auditors, several common themes have emerged.
Although organizations generally support efforts to strengthen accountability and improve stewardship of federal funds, many are seeking additional clarity regarding implementation and operational expectations.
Among the questions we hear most frequently are:
Organizations continue to evaluate whether new certifications, documentation requirements, and compliance expectations can be implemented efficiently without diverting resources from mission delivery.
Several proposed provisions provide federal agencies with broader authority over awards, monitoring, and termination.
Organizations are seeking additional guidance regarding how these authorities would be applied consistently across federal agencies.
States, local governments, universities, and nonprofit organizations serving as pass-through entities continue to evaluate expanded monitoring and oversight responsibilities.
Many organizations are considering how these provisions could affect staffing, oversight, internal controls, and the associated administrative costs.
Procurement continues to generate significant discussion.
Organizations are evaluating whether proposed revisions will require updates to procurement policies, documentation practices, and internal control procedures.
Even organizations supportive of the proposal recognize that significant policy revisions require thoughtful implementation.
Many are encouraging OMB to provide adequate transition periods and implementation guidance before new requirements become effective.
Why Organizations Should Consider Commenting
One misconception persists throughout the federal grants community:
“Our national association will submit comments for us.”
Trade associations play an important role in communicating the opinion of its organization and its members.
However, they cannot fully represent the operational realities experienced by every nonprofit organization, state agency, local government, university, hospital, research institution, or pass-through entity.
OMB benefits from hearing directly from organizations responsible for administering federal awards.
Individual experiences help regulators understand how proposed requirements function in practice and whether modifications could improve implementation while preserving accountability.
Organizations should not underestimate the value of practical examples.
Comments describing operational challenges, implementation costs, staffing implications, technology considerations, or unintended consequences often provide insights that cannot be gained from regulatory analysis alone.
Characteristics of an Effective Comment Letter
Organizations frequently ask whether they need legal counsel or regulatory specialists to prepare comments.
The answer is generally no.
The most influential comment letters often share several characteristics that:
- Identify the specific section being addressed.
- Explain how the proposal affects operations.
- Quantify administrative or financial impacts whenever possible.
- Distinguish between policy concerns and implementation concerns.
- Offer practical alternatives or suggested revisions.
- Maintain a respectful, solution-oriented tone.
The objective is not simply to criticize or endorse a proposal but to help improve the final regulation.
The comment period closes on July 13, 2026.
Organizations that receive, administer, or audit federal financial assistance should take this opportunity to:
- Review the proposed revisions most relevant to their operations.
- Engage finance, grants management, compliance, procurement, legal, and executive leadership.
- Discuss implementation challenges and operational impacts.
- Coordinate with governing boards and audit committees, as appropriate.
- Consider submitting a thoughtful, evidence-based comment letter.
The Uniform Guidance has evolved through collaboration among federal agencies, recipients, auditors, and other stakeholders. That collaborative process continues today.
With more than 40,000 comments already submitted as of June 30, 2026, the level of interest in these proposed revisions is clear. The remaining question is whether your organization’s experience and perspective will be part of the conversation.
The decisions made during this rulemaking process will shape the administration of federal financial assistance for years to come. Now is the time to help shape those decisions.
BDO’s Perspective
The proposed Uniform Guidance revisions represent an important opportunity to modernize federal financial assistance requirements and address evolving policy priorities.
At the same time, successful implementation will depend on balancing accountability with operational practicality.
Organizations administering federal awards understand better than anyone how federal programs function in practice. Their experience can help ensure that the final regulation strengthens oversight without creating unnecessary administrative complexity or unintended barriers to effective program delivery.
Whether your organization supports the proposal broadly or has concerns about specific provisions, this is an opportunity to participate in a process that will influence federal grants management for years to come.
How BDO Can Help
BDO’s Federal Grants, Nonprofit, State and Local Government, Higher Education, and Healthcare professionals continue to monitor the proposed Uniform Guidance revisions and assess their potential impact on recipients, pass-through entities, and auditors.
We are helping organizations evaluate the proposal, identify operational implications, facilitate governance discussions, assess internal control impacts, and develop practical implementation strategies. We also encourage organizations to participate in the rulemaking process by submitting thoughtful, constructive comments that reflect their unique operational experiences and support effective stewardship of federal resources.