ACTION NEEDED BY JULY 13

Tell OMB and Congress How
Your County Will Be Affected

Comment deadline: July 13

The Office of Management and Budget (OMB) has proposed rewriting 2 CFR Part 200, the Uniform Guidance. It governs every federal grant your county receives, and it's the biggest overhaul of these rules since 2013. Comments close July 13, 2026. Submit your comments, then call or write your representative and senators. Congress needs to hear from counties directly on this proposal.

Why Congress Needs to Hear from You

This rule does more than update paperwork. It gives OMB new authority to terminate grant awards mid-program, adds pre-award review requirements and reclassifies the Uniform Guidance as binding regulation instead of policy guidance. Congress oversees OMB, and representatives and senators need to hear how this rule will affect your county before it's final.

How This Could Play Out in Your County

1. A grant could be pulled mid-project
   The new termination authority means a county could be partway through a multiyear infrastructure, public health, or housing program funded by a federal grant and see the award cut off before completion, leaving the county to cover the gap or halt the work.
   
2. New pre-award reviews could slow down time-sensitive programs
   Added requirements, including E-Verify – the federal system used to confirm employees’ work eligibility – for all federal grants, mean more paperwork before a grant can even start. For programs tied to a hiring season, construction window, or emergency response, that added review time could delay services to residents.
3. Everyday county events could face new compliance risk
   The viewpoint-neutrality requirement applies to events on county-owned property even when no federal funding is involved. A town hall, library program, or community meeting held in a county-owned space could now trigger compliance questions county attorneys haven't had to consider before.
   

Key Provisions at Stake for Counties

• New authority for OMB to terminate grant awards mid-program
  
• Pre-award review requirements that could slow down applications, including E-Verify – the federal system used to confirm employees' work eligibility – for all federal grants
• Viewpoint-neutrality rules for events on county-owned property that do not receive federal funding
• More monitoring obligations for pass-through entities and subrecipients
  
• Uniform Guidance moves from policy guidance to binding federal regulation

What Your County Should Do Now

1. County attorneys: Read the proposed rule. Pay attention to the new termination authority, added pass-through obligations and the shift from guidance to binding regulation. We want to hear your perspective on the challenges and opportunities the proposed rule presents.
2. County officials: Use NACo’s template comment letter to submit comments (add your county’s own grant programs and local examples) and reach out to your representative and both senators - sharing your comment letter with them and outlining the impact the proposed rule would have on your county.

Submit by July 13 at Regulations.gov, docket OMB-2026-0034. Send your letters to Congress before the deadline.

NACo RESOURCES

Resource hub »

NACo's resource hub on the proposed rule includes analysis, webinar recording and slides, reference materials and more.

Template letter »

Use this customizable template to submit official comments to OMB before the July 13 deadline.

Contact your members of Congress »

Contact your representative and senators.

Submit comments »

Submit comments at regulations.gov using docket OMB-2026-0034.