There’s been a lot of discussion about OMB’s proposed changes to the Uniform Guidance. Excited people, concerned people, and plenty of people focused on the politics. Before you go too far down any of those roads, let’s establish a couple of facts.
These are proposed changes. Nothing is final. This is also a pretty normal part of the federal rulemaking process. OMB proposes updates, stakeholders comment, and a final rule gets issued. The Uniform Guidance has been revised multiple times since it was first released. The last one was finalized in 2024. What we’re seeing right now is the beginning of that process, not the end of it. That means organizations, state agencies, school districts, universities, nonprofits, auditors, and consultants all have an opportunity to weigh in before anything becomes final. That matters.
Now, I’ll be honest. I’ve been through a lot of regulatory cycles. As a former federal Program Officer and Compliance Team Lead who conducted onsite reviews of grant recipients across the country, I’ve watched administrations come and go, priorities shift, and guidance change. That part doesn’t surprise me. What did surprise me was the tone of the executive summary.
I’ve read a lot of these documents. It’s not typical to see citations to organizations like the Heritage Foundation in Uniform Guidance revisions. The policy arguments woven into the executive summary read more like a political document than a technical one. I’ll just say it: that’s unusual, and a lot of experienced grant professionals are going to raise an eyebrow at it. But here’s the thing. Don’t let that become the whole story for you.
Organizations don’t get audit findings because of their politics. They get audit findings because they couldn’t support costs, didn’t follow procurement requirements, had weak internal controls, failed to monitor subrecipients, or lacked documentation. That’s where your energy needs to go. The political tone of the executive summary will dominate the headlines. The actual regulatory changes are what will affect your organization. So let’s talk about those.
Five Things Worth Watching
1. Elimination of Fixed Amount Awards and Subawards
This one jumped out at me immediately. Fixed amount awards have been a useful tool for reducing administrative burden and simplifying grant management. If this proposal moves forward and that mechanism goes away, a lot of organizations are going to feel it in the form of increased reporting requirements and documentation expectations. I expect this provision alone to generate substantial public comment.
2. Increased Focus on Subrecipient Monitoring
This isn’t new, but the emphasis keeps growing. Having conducted onsite compliance reviews myself, I can tell you subrecipient monitoring has been a consistent problem area across federal programs for years. This proposal puts even more responsibility on pass-through entities to actively oversee organizations receiving federal funds. If you’re a state agency, university, school district, or nonprofit issuing subawards, read this section carefully.
3. Enhanced Conflict of Interest Requirements
The proposal tightens conflict of interest and disclosure expectations around procurement decisions, board relationships, contractor relationships, and governance practices. A lot of organizations have conflict of interest policies that haven’t been touched in years. This is a good time to pull those out and take a hard look at them.
4. Additional Documentation for Payment Requests
Documentation requirements are getting stronger throughout this proposal. OMB is moving toward requiring more justification and support for payment requests and financial transactions. If your organization already struggles with supporting records or cash management, pay close attention to this section.
5. Expanded Authority for Specific Award Conditions
Federal agencies already have authority under 2 CFR 200.208 to impose additional conditions on higher-risk recipients. This proposal appears to strengthen and clarify that authority. If your organization has recurring audit findings, questioned costs, or internal control weaknesses, increased monitoring could be coming your way.
Dave’s Take
The throughline of this entire proposal is accountability. More oversight, more documentation, more monitoring, stronger internal controls. Whether you think that’s a good thing probably depends on your role and where you sit. But I think most grant professionals can agree on this: organizations that already have solid policies and procedures, strong procurement systems, and effective monitoring processes are going to be fine. Organizations that have been getting by on informal practices are going to have a harder time.
Read the proposal yourself. Understand what it could mean for your organization specifically. And if you have something worth saying, submit comments during the public comment period. That’s how this process is supposed to work. The political noise around this one is going to be loud. Keep your eyes on the regulatory text.
About the Author
Dave Wickstrom is a former federal Program Officer and Compliance Team Lead who now helps organizations navigate federal grants through Team DWC. He has conducted onsite compliance reviews, managed large federal grant portfolios, served as the Executive Director of a federally funded nonprofit, and trained more than 15,000 unique grant professionals across the country. Having worked on both sides of the federal grants process, Dave’s approach to compliance has always been the same: it’s not about paperwork. It’s about building systems that protect funding, strengthen programs, and deliver results for the people being served.
