OMB Proposed Rule: 2 CFR Part 200 County Resource Hub
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On May 29, 2026, the Office of Management and Budget (OMB), in coordination with every federal grantmaking agency, published a proposed rule in the Federal Register rewriting 2 CFR Part 200 — the Uniform Guidance. This is the largest revision to federal grant rules since the Uniform Guidance was first published in 2013.
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What is this proposed rule?
On May 29, 2026, the Office of Management and Budget (OMB), in coordination with every federal grantmaking agency, published a proposed rule in the Federal Register rewriting 2 CFR Part 200 — the Uniform Guidance. This is the largest revision to federal grant rules since the Uniform Guidance was first published in 2013.
The Uniform Guidance governs every federal grant, cooperative agreement and pass-through award that counties receive — covering public safety, transportation, housing, public health, workforce development, child welfare, emergency management and more. The proposed rule introduces new national policy requirements, modifies grant termination authority, integrates grants administration with the Treasury Do Not Pay system, reclassifies 2 CFR Subtitle A from guidance to binding regulation, and revises cost principles, audit requirements and pass-through entity responsibilities.
On Aug. 2, the Senate unveiled their Fiscal Year (FY) 2027 Continuing Resolution (CR), which includes language postponing implementation of OMB's proposed rewrite of the Uniform Guidance (2 CFR Part 200). The comment period on the rule closed July 13, and NACo submitted formal comments on July 12 — this CR provision addresses what happens next, delaying the rule from taking effect while OMB reviews public input.
$1.1T
In federal grants
In federal grants to state and local governments in FY 2024 — all governed by 2 CFR Part 200
3,069
Counties
Receive federal grants and will be directly impacted by the proposed rule
Oct. 1, 2026
Effective Date
The rule is set to go into effect October 1, 2026, but a Senate CR could postpone implementation until Dec. 11.
Senate CR would postpone the Uniform Guidance rule, following NACo push
On August 8, the U.S. Senate passed a Continuing Resolution (CR) which includes language postponing implementation of OMB's proposed rewrite of the Uniform Guidance (2 CFR Part 200). The comment period on the rule closed July 13, and NACo submitted formal comments on July 12 — this CR provision addresses what happens next, delaying the rule from taking effect while OMB reviews public input.
NACo and other national, state and local organizations sent a joint letter to OMB in June urging OMB to delay the rule's effective date and conduct a formal federalism consultation before implementation. The Senate CR reflects that request.
To pass this CR, the House will need to reconcile any differences between the Senate’s CR and their own CR, which it passed on July 21 and does not include the OMB delay, before the bill can move to the president’s desk for a signature.
NACo will update this hub with the finalized effective-date language and next steps as the CR moves through Congress.
County Action Needed
Reach out to your House Representative
Call your Representative and urge passage of the Senate's Continuing Resolution, including the provision delaying the rule's effective date.
NACo Comments & Advocacy
NACo Comments on OMB's Proposed Rewrite of Uniform Guidance (2 CFR Part 200)
On July 12, NACo submitted formal comments to the Office of Management and Budget (OMB) on its proposed rewrite of 2 CFR Part 200, also known as Uniform Guidance, the government-wide rule governing federal grants administration. NACo's comments raise concerns about the rule's compressed timeline, its effective date and several provisions — including new termination standards, subrecipient monitoring requirements, viewpoint-neutrality and reliance on SAM.gov data — that could increase administrative burden on counties without a clear connection to program integrity.
NACo and other national, state and local organizations sent a letter to Senate leadership requesting language be included in the CR that would delay OMB proposed rule's effective date.
Resources
Explore resources and key reference documents for county staff and leadership.
Analysis
OMB Proposed Rewrite of 2 CFR: What Counties Need to Know
A concise summary of the most significant proposed changes and their potential fiscal and operational implications for counties acting as direct recipients and pass-through entities.
Template
Customizable letter to Congress
The public comment period on the proposed rule closed July 13, but counties should still work to communicate the rule's impact to their Members of Congress. Use this customizable template to tell them about the impacts the proposed rule will have on your county.
Slides
Webinar Slide Deck — Understanding the Proposed Rewrite of 2 CFR
Full slide deck from the June 17 briefing, covering major administrative changes, pre- and post-award rules, and revised audit requirements.
Official Text
Full Proposed Rule — Federal Register (Docket OMB-2026-0034)
The complete text of OMB's proposed revisions to 2 CFR Subtitle A, including conforming changes to all federal grantmaking agencies in Subtitle B. Published May 29, 2026.
Coalition Letter
NACo Leads Coalition Letter Requesting 45-Day Comment Extension
NACo joined a group of national associations in requesting OMB to extend the public comment period beyond July 13.
Coalition Letter
NACo Sends Coalition Letter to Senate Leadership Requesting an OMB Rule Delay in CR
NACo and other national, state and local organizations sent a letter to Senate leadership requesting language be included in the CR that would delay OMB proposed rule's effective date.
Resource
What Counties Should Do Ahead of the Final Rule
OMB is reviewing the nearly 500,000 comments left during the public comment period, but counties don't need a final rule in hand to start getting ready. Follow these steps to prepare, regardless of exactly when or how OMB finalizes the regulation.
Resource
CR Talking Points
Counties should reach out to their House Representative now, urging them to pass the Senate's Continuing Resolution which includes language delaying the OMB Uniform Guidance rule. Use these talking points to advocate for why the CR must be passed.
Watch the webinar
Understanding the Proposed Rewrite of 2 CFR: What the OMB Uniform Guidance Proposed Rule Means for Local Governments
June 17, 2026 · 2–3 p.m. ET
A substantive overview of the proposed rule, its operational implications for local governments and the key provisions warranting attention before the July 13 comment deadline. Speakers outlined major administrative changes, new pre-award and post-award rules and revised audit requirements.
County Comments
Communicate the rule's impact on your county to Congress
The public comment period on the proposed rule closed July 13, but counties should still work to communicate the rule's impact to their Members of Congress.
County attorneys should continue monitoring the rule's grant termination authority, expanded pass-through entity obligations, and reclassification of 2 CFR Subtitle A from guidance to binding regulation as the CR advances.
This customizable template is designed for county commissioners, executives and administrators to communicate those impacts to Congressional members. Customize with your county's name, the specific federal grant programs you administer, and any local examples of how the proposed changes would affect service delivery, staffing or budget planning.
Latest from NACo
Explore the feed below pulling the latest from NACo on the OMB proposed rule, and for more visit the Intergovernmental Affairs topic page.