On May 29, 2026, the Office of Management and Budget (OMB) proposed a sweeping rewrite of 2 CFR Part 200 (the “Uniform Guidance”). We want to ensure our research and finance community is fully briefed on these potential shifts, which represent a major restructuring of federal award administration.

Here is a summary of all the key proposed revisions:

• From Guidance to Binding Regulation: OMB proposes reclassifying 2 CFR Part 200 as a binding federal regulation. Future amendments would immediately apply government-wide on a single effective date without waiting for individual agency codification, centralizing authority and narrowing compliance transition windows.
• Political Appointee Pre-Issuance Review: A senior political appointee at each federal agency would be required to review discretionary awards before issuance to ensure they align with presidential policy priorities.
• Discretionary Termination and Suspension: Agencies would gain broad authority to suspend or terminate awards based on “national interest” or shifting priorities, introducing a FAR-style “stop-work” order mechanism.
• Major Revisions to Cost Principles:
  • Publication Costs and Open Access Fees: Under a reversal of current standards, publication costs and open-access fees would generally be unallowable without case-by-case agency pre-approval.
  • Subscriptions and memberships: Journal subscriptions and professional society memberships would become unallowable, impacting library budgets and negotiated indirect cost (facilities and administrative, or F&A) rates.
  • Conferences: Mandatory prior approval would be required for all conference-related expenses.
• Policy and Ideological Prohibitions: The proposal bars federal funding for diversity, equity and inclusion (DEI) initiatives, research on gender ideology and disparate-impact liability research.
• Elimination of Fixed-Amount Awards: The rule proposes completely eliminating fixed-amount awards and subawards, significantly escalating administrative burdens for managing subrecipients.

Looking Ahead

While F&A rate calculation methods remain intact for now, the administrative burden and financial risks to our research enterprise could increase significantly. NC State has actively collaborated with peer institutions and national bodies, including the Council on Governmental Relations (COGR) and the Association of Public and Land-grant Universities (APLU), to submit comprehensive institutional feedback before the public comment period closed on July 13, 2026. We will keep you updated as we prepare for the targeted October 1, 2026, effective date.