# Uniform Guidance The **Uniform Guidance** (2 C.F.R. Part 200, formally *Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards*) is the government-wide OMB regulation that governs federal grants and cooperative agreements. It covers: - how funding opportunities are announced, - what costs are allowable, - how indirect costs are recovered, - how recipients monitor subrecipients, - how awards are closed out, and - the [[Single Audit]]. Issued in December 2013, it replaced eight separate OMB circulars with one rulebook. It is the plumbing under most federal assistance to states, universities, hospitals and nonprofits. ## Why a grants regulation became a front line Contracts have a long-settled doctrine of [[Termination for Convenience]]: the government can walk away and pay for work done. Grants historically had nothing like it. The Uniform Guidance is where that gap was opened, one revision at a time: | Revision | What changed | |---|---| | **2020** (first Trump term) | § 200.340 gained a ground for terminating an award that "no longer effectuates the program goals or agency priorities" | | **2024** (Biden, effective Oct 1, 2024) | Renumbered to § 200.340(a)(4) and narrowed. For new awards, agencies must write the ground clearly into the award's terms before they can use it | | **Aug 7, 2025** | [[Executive Order 14332]] directs agencies to write termination-for-convenience language into awards and orders OMB to revise Part 200 to match | | **May 29, 2026** | OMB's proposed rewrite of Part 200 | The priorities clause was the stated basis for billions of dollars in 2025 terminations of research, public-health and climate grants ([[How a Federal Agency Is Dismantled]]). Because it is a termination under the award's own terms rather than a policy change, it works without a rulemaking, a statute or a vote. ## The May 29, 2026 rewrite OMB's proposed rule (comments closed July 13, 2026; target effective date October 1, 2026; about 49,000 comments by early July) would change Part 200 in three ways: - **Terminate for "the national interest."** Agencies could end an award if it no longer effectuates "program goals, Federal agency priorities, or the national interest" *as judged at the time of termination*. - **Political pre-issuance review.** "Senior appointees" would have to certify that funding opportunities and awards "demonstrably advance the President's policy priorities." This carries forward the political sign-off in EO 14332. - **Content bars and new conditions.** Awards could not fund activities promoting "racial preferences" or "gender ideology," and every recipient would have to use E-Verify. It leaves [[Indirect Cost Rate]] negotiation untouched, citing congressional direction to study that question further. It is one front in the grants fight where Congress has pushed back. ## The court's answer, and its limit On **July 17, 2026** the District of Massachusetts ruled for 20 states, three governors and D.C. in their suit against OMB. It held that § 200.340(a)(4) does **not** allow termination over goals or priorities identified *after* an award was made, reasoning from the regulation's own notice requirements and from [[Spending Clause]] notice doctrine. The relief was **declaratory only**. No terminated grant was reinstated. The rewrite would also replace the regulatory ground the ruling stands on for every award made afterward. The pattern matches the rest of the dismantling toolkit: the court describes the old rule correctly just as the rule is being rewritten. ## See also - [[Federal Grant Lifecycle]] · [[How a Federal Agency Is Dismantled]] · [[Executive Order 14332]] - [[Termination for Convenience]] · [[Indirect Cost Rate]] · [[Single Audit]] · [[Spending Clause]] - [[Office of Management and Budget]] · [[Russell Vought]] · [[NIH]] · [[National Science Foundation]]