Client Alert: Key Changes and How to Comment on Proposed Updates to Uniform Guidance

By , | Published On: October 5, 2023

OMB Issues Proposed Rule for Federal Awards – Act Before December 4, 2023

The Office of Management and Budget (“OMB”) has officially released the proposed rule to update the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (“Uniform Guidance”) as codified at 2 C.F.R. Part 200. This important development is detailed in the Federal Register notice, which you can access here. If you wish to provide comments, please note that you have until December 4, 2023, to do so. Instructions on how to submit your comments can be found in the notice.

While this update doesn’t constitute a comprehensive rewrite of the Uniform Guidance, there are significant proposed changes that warrant attention. In a recent client alert (available here), we highlighted some of these changes. Additionally, our attorneys conducted a webinar on October 4, providing a comprehensive walk-through of key observations from the pre-publication version that OMB made available last week.

If you missed the webinar and are interested in reviewing it on demand, you can access it here: OMB Proposed Uniform Guidance Changes.

In the coming week, our attorneys will be reviewing the official proposed rule in comparison to the pre-publication version to identify any additional noteworthy items.

Your input is valuable in shaping these important regulations. For any questions or assistance with comments, please contact Scott S. Sheffler ( or Ted Waters ( or call 202.466.8960.