Form 690: HHS Currently Accepting Comments on Major Changes

On April 24, 2026, HHS published a Federal Register notice proposing significant revisions to its Assurance of Compliance form, HHS-690 (Form 690). The current Form 690 is set to expire on April 30, 2026. Comments on the proposed changes are due no later than May 26, 2026.

HHS requires most grantees, including all health center grantees, to sign and submit Form 690 to certify that they will comply with the listed federal laws and regulations, including Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act, Title IX, Age Discrimination Act, and Section 1557 of the Affordable Care Act. Subrecipients and contractors are generally required to sign Form 690 only when the contract is funded with federal grant dollars. 

HHS has proposed the following substantive revisions:

1. Clarifying that prohibitions on sex-based discrimination under Title IX and Section 1557 include discrimination based on pregnancy and do not include discrimination based on sexual orientation and gender identity;
2. Adding a new provision addressing religious discrimination;
3. Clarifying that Form 690 applies to entities that receive any federal funds, rather than only when the funds support a specific program or activity; and

4. Including a condition that violating the assurance may give rise to False Claims Act liability.

These updates are proposed as part of the Paperwork Reduction Act process, under which HHS must obtain approval from the Office of Management and Budget (OMB) to continue using the form.

A copy of the proposed form and related implementation materials is available by contacting the OCR as described in the notice, or by contacting Joella Roland at Joella.Roland@powerslaw.com.