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Staff warns proposed 2 CFR 200 rule could make federal grants easier to terminate
Summary
County public-health staff told the board a proposed federal rule would convert 2 CFR 200 (uniform guidance) into a regulation, increase federal agency authority and could allow termination of grants if they no longer match agency priorities.
Jared briefed the board on a proposed federal rule posted to the Federal Register that would change 2 CFR 200, often called the uniform guidance, into a formal regulation and flagged potential impacts for county grant funding.
"They're changing it from uniform guidance to regulation, which gives it more authority," Jared said, and read a proposed termination clause: "If it is found that it does not effectuate program goals, federal agency priorities, or the national interest as they exist at the time of termination." He said that change could make multi-year grants less secure if federal priorities change.
Jared said MACo has engaged in negotiations with the state and that the state chose to extend the current master contract for another year rather than adopt the state's earlier 10-year draft. He noted the proposal also removes many fixed-amount (formula or block) awards unless those awards are protected by federal statute, and said the county’s maternal-child-health block grant is protected by statute while other grants (IAP) may face more restrictive, reimbursable requirements.
