County staff outlines OMB proposal to reclassify grant guidance as binding regulation

County staff summarized proposed Office of Management and Budget changes to 2 CFR part 200 at the Oklahoma County Board of County Commissioners’ policy and governance meeting, saying the May 29 proposal would make a series of grant-administration rules binding and expand federal oversight of awards.

Jessica, a county staff member who presented the overview, described three main objectives of the proposal: improving transparency and accountability, reclassifying many provisions from guidance into binding regulation, and reducing some subrecipient burdens. "Clarifying that the rules are are binding regulations, not just guidance," she said, describing a change in terminology from "uniform guidance" to "uniform regulation." The presenter said these shifts would centralize rules across federal agencies and could require agencies that previously used separate grant processes to adopt the new subparts in 2 CFR.

Jessica flagged several items likely to affect grant recipients: an expanded discretionary termination authority that, in the presenter’s words, "literally um basically allows any federal agency to terminate the award if it is determined that the award award no longer serves the program goals or the national interest," strengthened post-award recipient monitoring and risk-based site visits, tighter documentation requirements for cost allowability (including restrictions on using federal grant dollars for advertising, conferences, memberships, lobbying and similar items without prior approval), and broader payment-integrity checks through Treasury’s Do Not Pay system and additional E-Verify requirements.

The presenter also noted procedural changes for discretionary grants: agencies would need to list discretionary funding opportunities publicly through a notice of funding opportunity (NOFO) and include an executive summary of up to 500 words. She said some Recovery Act/ARPA–related language will be removed as that program winds down. Jessica emphasized that the county's current award-management and monitoring practices largely already align with the proposed requirements and that the rule would not take effect until it is finalized (the presenter indicated an effective date in 2027 if finalized).

Accenture consultant Ms. Danny told the board she had no ARPA-specific updates for this meeting and deferred to the OMB update. Board members thanked staff for the summary; the board recorded no formal action on the proposed OMB changes during the meeting.