Take Action: Share Your Voice on OMB's Federal Grant Restriction Proposal

Recently, the White House Office of Management and Budget (OMB) published a proposed rule, "Regulation for Federal Financial Assistance," that would revise the Uniform Guidance governing federal grants (2 CFR Part 200). Several proposed changes would affect how grant recipients participate in association activities. OSAP has previously shared this information with our members. 

Now, alongside the American Society of Association Executives (ASAE) and the Community Impact Coalition, we're asking you to take action if you believe this will impact your organization or your members' businesses.  

Here are two resources to help support public comment participation in a response to these proposals: A comment guide that OSAP was instructed can be shared with ASAE members and non-members alike to help organizations craft their own comments and an association questionnaire to solicit member feedback on the impact of these provisions on their organizations.

The member questionnaire has a response deadline of July 6, 2026. Final public comments are due to OMB on July 13, 2026.

For more information, please read the content below: 

OMB Proposed Grant Restrictions Overview:

Some of OMB's proposed provisions would affect associations whose members use federal grants to pay for the association's services, including new restrictions on membership dues, professional and academic subscriptions, conference attendance, journal and open-access publication charges and a new category of unallowable "issue advocacy" and "public messaging" costs. 

Other provisions would affect associations that directly receive federal grants, including senior political review of awards before issuance, a new viewpoint-neutrality standard for event services, expanded "reputational" monitoring of sub-recipients and affiliates, a ban on fixed-amount sub-awards and broad authority to terminate awards at will.

By making membership dues, conference attendance and journal publication charges unallowable or subject to advance approval, the proposals discourage the very inputs that make federally funded work effective: the associations that set standards and provide training and credentialing, the conferences where results are disseminated and the technical workforce is trained and the publication of findings so the government-funded research gets used.

The proposals would also create significant new administrative burden for both agencies and grant recipients while making the awarding process unpredictable, as awards would turn on undefined criteria and added layers of review.

OMB is accepting comments on these proposals. Comments must be submitted electronically at www.regulations.gov to docket OMB-2026-0034, Regulation for Federal Financial Assistance. The comment deadline is July 13, 2026.

New Resources for OSAP Members and ASAE Members/non-members:

 The national organization is sharing resources for OSAP members and/or ASAE members/non-members interested in engaging in the public comment process:

• Member Comment Guide: This guide summarizes provisions that are concerning. The guide also includes instructions on commenting and prompts to help respondents craft their own comments.
• Member Questionnaire: This form is designed to collect responses from parties regarding their concerns with specific provisions in the grant restrictions proposal. ASAE will use these responses to inform its organization's comments and shape additional advocacy activities. Please respond with information on as many provisions as are relevant to your own organization.

To allow ASAE to implement feedback from the questionnaire, the response deadline is July 6, 2026.

As comments are finalized, OSAP, working in conjunction with ASAE and the CIC, will share additional information. If you have any additional comments, please contact ASAE Senior Director of Public Policy Kyle Hayes via email.