08/28/2026
Federal award recipients: OMB's proposed rewrite of 2 CFR Part 200 could reshape how you manage audit and compliance responsibilities. It's the most significant overhaul of Uniform Guidance since 2014.
We broke down what governments, schools, and nonprofits need to know.
Here's what stands out:
- Uniform Guidance shifts from a guidance framework to a government-wide regulation, meaning future OMB revisions could apply across programs automatically.
- New payment justification and E-Verify requirements would apply to recipients and subrecipients alike.
- Cost principles tighten around advertising, conferences, memberships, and subscriptions. These costs aren't automatically unallowable, but you'll need to document why they further the award.
- Subrecipient monitoring becomes a core compliance risk. Every downstream relationship must be classified and reported.
- Green Book and COSO would no longer be required internal control frameworks, placing more weight on your own judgment.
The throughline? Responsibility keeps shifting toward you, the recipient.
Going forward, it won't be enough to achieve compliance. You'll need to demonstrate how you interpreted the rules, built controls around them, and documented every judgment along the way.
The good news: With the right processes in place, this is well within reach for teams already familiar with Single Audit compliance. The time to review your documentation and approval processes is now, before a final rule lands.
Read the full breakdown here: https://hubs.la/Q04vznSw0
Have questions about how these changes could affect your organization? Reach out to your Rehmann advisor. We're here to help you navigate what's ahead.
The proposed Uniform Guidance rewrite shifts more compliance responsibility to recipients. Learn what it means for your audit and documentation practices.
