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.
$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
July 13
Current deadline
Current deadline to submit comments via regulations.gov (docket OMB-2026-0034)
County Action Needed
Deadline to submit comments is July 13, 2026
NACo urges county attorneys to review the proposed rule and county officials to submit comments.
The proposed rule's new grant termination authority, expanded pass-through entity obligations, and reclassification of 2 CFR Subtitle A from guidance to binding regulation carry significant legal and fiscal implications for counties. County attorneys should assess the rule's provisions — particularly around award termination, viewpoint-neutrality requirements, and sub-recipient liability — before your county submits comments. You can use NACo’s template letter below — personalized with your county's grant programs and local impact examples.
Office Hours
Share How the OMB Proposed Rule Affects Your County
NACo wants to hear directly from county officials about the real-world impacts of OMB's proposed rewrite of 2 CFR Part 200. Your feedback will inform NACo's formal comment letter before the July 13 deadline.
Sessions run 4–5 p.m. on June 25, June 30, July 2 and July 7.
Join via Microsoft Teams
Meeting ID: 270 302 425 517 545 | Passcode: 4oL9XY9q
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.
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
Use this customizable template to submit official comments to OMB before the July 13 deadline.
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.
Take action: Submit your county’s comment
Use this customizable template to submit official comments to OMB before the July 13 deadline.
County Official Comment Letter Template — OMB Proposed Rule on 2 CFR Part 200
This customizable template is designed for county commissioners, executives and administrators to submit formal comments to OMB. 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. Submit comments at regulations.gov using docket OMB-2026-0034.
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.