Trump Administration Federal Grant Oversight Proposal Expands Senior Review of Awards
The Office of Management and Budget released a 400-plus page rewrite of 2 CFR 200 on Friday, and the proposed trump administration federal grant oversight plan would require federal agency heads to designate senior appointees to pre-review all discretionary awards. The change would put political appointees or other senior officials into a larger role before grants are issued.
OMB 2 CFR 200 Rewrite
OMB said the revisions aim to ensure that basic American principles of equality and equal opportunity are upheld throughout all stages of the award making process and that unlawful discrimination is no longer permitted. The agency also said the proposal would clarify the regulatory status of its requirements, set out the process for future updates to the governmentwide requirements, and reduce recipient burden.
The rewrite is the second time in two years that OMB has updated 2 CFR 200. The 2024 update focused on plain English and on improving grant application access for underserved communities, but the new proposal follows President Donald Trump’s August executive order, Improving Oversight of Federal Grantmaking.
Dan Ramish On Political Review
Dan Ramish, an attorney and partner with Haynes Boone, said one of the most significant changes is the bigger role for political appointees or other senior officials in the discretionary grants process. He said, “This is ensuring policy alignment.”
Ramish also said, “There is a case to be made in both directions, codifying a political role that may or may not have already existed versus being more explicit to have more political involved in dec.” His point captures the central tradeoff in the proposal: agencies would no longer be leaving pre-issuance review to lower-level grant staff alone.
July 13 Comment Deadline
The proposed changes also remove DEI and other identity-based concepts from grantmaking, according to the Trump administration’s position on the rewrite. Federal grant-making agencies would then propose conforming changes to their own adopting regulations, and some agencies and other entities would establish new adopting regulations or policies.
Comments on the proposed rule are due by July 13. For agencies, grant recipients, and applicants, the immediate task is to review the new pre-issuance process and the agency-level rules that will follow if the proposal is finalized.
