On September 2, 2026, the President signed into law a bipartisan Continuing Resolution (CR) funding the federal government through December 11, 2026. The CR also provides that the Office of Management and Budget (OMB) may not issue “a rule to revise the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards,” until December 11, 2026. This means the proposed and highly anticipated updates to the Uniform Guidance (2 C.F.R. Part 200) are on hold until at least mid-December.
Why It Matters for Your Health Center
OMB’s proposed rule would make significant changes to federal grant administration, including expanding federal oversight of grant awards and giving agencies, including the Department of Health and Human Services (HHS), more discretionary control at every stage of the grant lifecycle:
While the CR’s delay of OMB’s proposed rule reflects congressional concern over its scope and impact, it does not alter the proposed rule itself or limit its effect on grantees if the rule is ultimately finalized as written.
Health centers should use this time to continue advocacy efforts, including contacting members of Congress and relaying concerns with the proposed rule. Health centers should continue to follow current Uniform Guidance and existing award terms while monitoring OMB and HHS for further updates, especially as December 11, 2026, approaches.
OMB’s proposed rule would make significant changes to federal grant administration, including expanding federal oversight of grant awards and giving agencies, including the Department of Health and Human Services (HHS), more discretionary control at every stage of the grant lifecycle:
- Before the award: Political appointees would sign off on discretionary awards, with their judgement overriding other reviewers.
- During the award: Agencies would be permitted to incorporate policy priorities into federal grant requirements, creating new compliance obligations for recipients.
- Terminating the award: Agencies would have expanded authority to terminate federal grant awards if the award “no longer advances the agencies priorities or the national interest.”
While the CR’s delay of OMB’s proposed rule reflects congressional concern over its scope and impact, it does not alter the proposed rule itself or limit its effect on grantees if the rule is ultimately finalized as written.
Health centers should use this time to continue advocacy efforts, including contacting members of Congress and relaying concerns with the proposed rule. Health centers should continue to follow current Uniform Guidance and existing award terms while monitoring OMB and HHS for further updates, especially as December 11, 2026, approaches.
Contact us to learn more:
DIANNE PLEDGIE
dianne.pledgie@powerslaw.com
Sydney Habegger
sydney.habegger@powerslaw.com
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