On May 29, 2026, the Office of Management and Budget, together with roughly 40 federal agencies including HUD, published a proposed rule that would rewrite the government-wide regulations for federal financial assistance, including 2 CFR Part 200, commonly known as the Uniform Guidance. Public comments are due in just a few days by July 13, 2026, and OMB has stated it intends the final rule to be effective by October 1, 2026, so that a single set of requirements applies to awards made in fiscal year 2027. This post summarizes what the proposal would change, where the rulemaking stands, and what housing agencies can do now. 

Background on the Proposed Rule 

The Uniform Guidance has governed federal grant administration since 2013. It sets the baseline requirements for how awards are issued, managed, monitored, audited, and closed out. If your agency administers HUD funds, this is the rulebook underneath your procurement standards, internal controls, payment processes, and Single Audit. 

The proposed rule, published at 91 FR 32198 under the title Regulation for Federal Financial Assistance, would revise Part 200 alongside dozens of agency chapters across Title 2. OMB revised the framework in 2020 and again in 2024; this breadth of change is broader than either. The proposal incorporates requirements from a series of recent Executive Orders, including new review steps and funding prohibitions. It would also clarify that the Uniform Guidance operates as an OMB regulation with more standardized government-wide requirements rather than guidance each agency implements independently. OMB organizes the proposal around three stated objectives: improving transparency, accountability, and oversight; clarifying the regulatory status of the text; and reducing recipient burden.  

One important legal question remains unresolved for some HUD programs. Several housing industry organizations have noted that Public Housing and Housing Choice Voucher programs operate under Annual Contributions Contracts rather than traditional federal grant agreements and have questioned whether every provision of the revised Uniform Guidance would apply to those programs. HUD has not yet clarified how the final rule would interact with those contractual arrangements. 

What the Proposal Would Change for Housing Agencies 

Most of the proposal’s weight lands on documentation, payment processes, and oversight. The changes most relevant to housing agencies: 

• Payment justification. Federal agencies and pass-through entities would be required to exercise due diligence before issuing payments, including requiring a justification for payment requests and screening through Treasury’s Do Not Pay system. 

• Expanded award conditions. Federal agencies could impose additional award-specific conditions when greater oversight is warranted, including reimbursement rather than advance payments, enhanced financial reporting, increased project monitoring, technical assistance, and additional prior approvals. 

• Subaward reporting. Federal dollars transferred by a recipient to affiliates, subsidiaries, or other related organizations would be tracked as subawards and reported on SAM.gov, with a documented subrecipient or contractor determination behind each transfer. Agencies with affiliated nonprofits or instrumentalities would feel this directly. 

• Fixed amount awards eliminated. The proposal would eliminate fixed amount awards and subawards, on the grounds that they involve no routine monitoring of actual costs and no financial reporting. 

• Pre-issuance review. Discretionary awards would undergo additional review by senior agency officials before issuance, consistent with Executive Order 14332. 

• Expanded termination authority. Agencies would retain discretion to terminate a discretionary award that is not effective at achieving program goals or agency priorities, or that the agency determines is no longer in the Federal Government’s interest, with clearer notice requirements. The proposal also specifies that formal objection, hearing, or appeal procedures would not necessarily be available for every termination decision, depending on the basis for the action. 

• Recipient history. A recipient’s record of financial management and past practices would carry more weight in award decisions. 

• Procurement, controls, and audit. The proposal also revises procurement standards (sections 200.318 through 200.324), internal controls (section 200.303), and audit requirements under subpart F. For many housing agencies, procurement policies will likely be the first operational area requiring review if the rule is finalized. AMA will break down the specifics for housing agencies when the final rule publishes. 

One area the proposal does not touch: indirect cost rates. OMB states that fiscal year 2026 appropriations language preserved existing negotiated rates, and it has deferred any changes to a possible future action. 

Where the Rulemaking Stands 

The comment window is short for a rule of this size. Comments are due July 13, 2026, 45 days after publication. Several national organizations representing local governments and grant recipients have requested extensions of 45 to 90 days. As of this writing, no extension has been granted, and the docket approaching 99,000 comments. 

OMB’s target effective date of October 1, 2026 is a stated intention, not a certainty. Rules of this scope often shift during finalization, and legal challenges are possible. Treat the date as a planning marker, not a deadline set in stone. 

What Housing Agencies Can Do Now 

Nothing in the proposal creates a new obligation today. The current Uniform Guidance remains in effect. The practical question is readiness: if the final rule lands close to the proposal, the agencies in the best position will be the ones whose documentation already holds up. 

A few places to look first: 

• Review how payment requests are documented and justified today, and whether that record would stand on its own. 

• Inventory every transfer of federal funds to an affiliated entity, and confirm each has a documented subrecipient or contractor determination. 

• Pull a recent procurement file and check whether the documentation would stand on its own under a tighter standard. 

• Review procurement policies and procedures to identify provisions that may require revision if the Uniform Guidance changes are finalized. 

• Confirm your internal controls documentation is current, including how information and systems are safeguarded. 

• Know your findings history. Under the proposal, it follows you into future award decisions. 

Each of these is work an agency can start without waiting for the final rule, and each one strengthens the record regardless of where the rulemaking ends up. 

Resources to Support Your Team

AMA tracks federal rulemaking that affects housing operations and translates it into the operational steps agencies need. Policy Alerts subscribers receive a breakdown when the final rule publishes.

When Additional Support May Make Sense

For agencies reviewing their readiness ahead of the final rule, AMA’s team supports documentation reviews, internal control assessments, subrecipient monitoring structure, and procurement file reviews built around federal requirements. If the proposal’s documentation standards would strain your current capacity, that gap is easier to close now than after an award decision depends on it.

Additional Reading

• Regulation for Federal Financial Assistance, 91 FR 32198 (May 29, 2026): https://www.federalregister.gov/documents/2026/05/29/2026-10817/regulation-for-federal-financial-assistance
• Public comment docket OMB-2026-0034 at regulations.gov

This article is intended as general information and does not replace the proposed rule text, federal regulations, or official guidance.