The Federal Office of Management and Budget (OMB) has proposed rewriting 2 CFR Part 200, the Uniform Guidance and the section governing federal grants counties receives. NACo is encouraging counties to submit a comment to OMB before the Monday, July 13th comment deadline, asking OMB to publish a fiscal impact analysis on states and localities before finalizing the rule, and to delay implementation until at least Oct. 1, 2027, so counties have time to prepare. NACo is asking counties to send a letter to their members of Congress on this proceeding as well.
RCRC will be joining with CSAC and other stakeholders on a letter to OMB outlining concerns that the proposed rule would undermine funding certainty; subject core county programs to arbitrary considerations; and create significant new administrative and fiscal burdens. Among the provisions of the proposed rulemaking are: expanded authority for grants to be terminated mid-program; pre-award and pre-payment requirements; and more monitoring obligations for pass-through entities and subrecipients.
A template letter from NACo is available HERE. More information about submitting a letter is available HERE.
For additional information, contact RCRC Policy Advocate, Eric Will.