Overview
The Senate’s bipartisan Continuing Resolution (CR), released on August 2, 2026, includes a provision that would temporarily delay implementation of the Office of Management and Budget’s (OMB) proposed revisions to the Uniform Guidance (2 CFR Part 200) through December 11, 2026. If enacted, the provision would preserve the current federal grant management framework while Congress completes appropriations negotiations and OMB continues reviewing public comments on the proposed rule.
The Continuing Resolution must still be reconciled with the House version before a final funding measure can be sent to the President for signature. As negotiations continue, the provision delaying implementation of the Uniform Guidance revisions could be modified, retained, or removed.
Why It Matters
Many Presidents Forum institutions receive federal grants and other forms of federal financial assistance that are governed by the Uniform Guidance. The proposed revisions represent one of the most significant updates to federal grant administration in more than a decade, with potential implications for grant oversight, compliance requirements, and the administration of federal financial assistance across agencies.
If the delay is included in the final appropriations measure, institutions will continue operating under the existing Uniform Guidance through December 11, 2026. This would provide additional time to evaluate the proposed changes, monitor federal guidance, and prepare for any future implementation requirements.
What Institutions Should Monitor
Over the coming months, Presidents Forum institutions should monitor several developments:
- Whether the final Continuing Resolution retains the provision delaying implementation of the Uniform Guidance revisions.
- Any announcements from OMB regarding a revised implementation timeline or changes to the proposed rule following its review of public comments.
- Guidance issued by federal agencies and higher education associations regarding compliance expectations during the delay period.
- Potential operational, compliance, and administrative impacts if the revised Uniform Guidance ultimately takes effect.
Looking Ahead
Until a final appropriations measure is enacted, institutions should continue complying with the current Uniform Guidance requirements. The Presidents Forum will monitor congressional negotiations, OMB rulemaking, and related federal guidance, providing updates as additional information becomes available.