Submit a Public Comment: Proposed Rule Change - Regulation for Federal Assistance

What It Is

The Office of Management and Budget, alongside 46 federal agencies, proposed the Regulation for Federal Assistance under the Trump administration's guidance. The agencies claim that this proposal will "improve transparency, accountability, and oversight for Federal awards across the Federal Government,” by introducing legal barriers and a stopgate for the federal government to cut funding for any entity that goes against their agenda. In practice, this would require an additional prior review before a federal grant recipient can receive any government funding. The award must pass a "pre-issuance review" conducted by a political appointee—not a career expert or peer reviewer—to ensure it is "consistent with applicable law, Federal agency priorities, and the national interest." Criteria for denial of funding to an organization, as defined by this proposal, include: having racial preference, promoting gender ideology, illegal immigration, or anti-American values. The deadline to submit public comments is Monday, July 13th, 2026.

Why It Matters

Philanthropy serves as a partner and investor in the nonprofit and public sector, ensuring that grantees have the support to provide essential services and advance equitable outcomes in communities across the nation. As proposed, these changes to the Uniform Guidance would introduce significant instability, administrative burden, and politicization into the federal grantmaking process, ultimately undermining the effectiveness of both public and philanthropic investments. As a result, many qualified organizations may decline participation, leading to disruptions in essential services—including housing, health, education, and disaster recovery—in communities nationwide. Philanthropy will not be able to fill these gaps in funding or infrastructure support.

This broad and unspecific criterion leaves government funding in the hands of political appointees and at the discretion of the executive administration in power. It is another vehicle for unilateral control and undemocratic discretion of government funding, undermining competitive, merit-based granting. This change will inevitably impact the sustainability and financial security of nonprofit organizations and pose a constant threat of surveillance to the nonprofit sector, affecting their ability to deliver critical services to their constituents.

Call to Action

We invite your organization to submit a public comment by July 13th, 2026 and stand with communities impacted by this inequitable harm. For proposed rule regulations, the quantity and individuality of public comments is imperative. We understand that the federal government is increasing its use of generative artificial intelligence tools in the agency rulemaking process, including the analysis of submitted comments from the public. To be counted as a unique, individual comment, we recommend writing the public comment in your own words, using examples specific to your organization as often as possible. You may also request that OMB disclose its usage of AI tools in the development of the rule on federal assistance.

Submitting a public comment is within a foundation's advocacy rights and is NOT considered lobbying. Learn more at Alliance for Justice's Bolder Advocacy Resources or the United Philanthropy Forum's resource on Regulatory Engagement for Philanthropy. See the link below for an example of the language foundations can use to submit their own comments.

Download Public Comment Letter Template

We also encourage organizations to sign on to The California Endowment's letter by July 9th, 2026.

Sign-on to TCE's Letter