CAPLAW and the National Community Action Partnership (NCAP) will be submitting joint comments on the Office of Management and Budget’s (OMB) proposed changes to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Our letter reflects specific comments, support, objections, and requests for clarification on a number of topics, including the award application process, incorporation of executive orders and agency priorities, grant termination, subaward reporting, and prior approval for certain previously allowable costs.
Please note that this is a working draft, and we may make minor revisions before submitting our final comments.
On May 29, 2026, OMB published proposed revisions to the Uniform Guidance covering Title 2 of the Code of Federal Regulations, including 2 C.F.R. Part 200. If implemented, the proposed changes will affect all federal grant recipients, including the Community Action Network. For an overview of the proposed revisions, see CAPLAW’s News Alert and recording of CAPLAW’s webinar.
Comments are due on or before July 13, 2026. Comments can be submitted on regulations.gov. For those wishing to submit comments, you are welcome to use the ideas and positions reflected in our joint comments. Please consider adjusting the language in individual submissions, rather than copying large sections of the text, to reflect your organization’s unique experience and perspective.
