HomeMy WebLinkAbout071326 email - Fwd_ Alert_ NACo Submits Comments on OMB Uniform Guidance Proposed RuleALERT: BE CAUTIOUS This email originated outside the organization. Do not open attachments or click on links if you are not expecting them.
Good morning.
I wanted to share with NACo’s concerns and recommendations regarding the OMB Uniform Guidance Proposed Rule. Eryn Hurley, the Chief Government Affairs Officer has provided a copy of
their public comments. Thank you.
Crystal Ellerbe
direct dial: (202) 862-7103
company main: (202) 862-7100
cellular: (202) 367-6012
email: cellerbe@acornwdc.com
website: acornconsulting.com
Begin forwarded message:
From: Eryn Hurley <EHurley@naco.org>
Subject: Alert: NACo Submits Comments on OMB Uniform Guidance Proposed Rule
Date: July 13, 2026 at 10:38:46 AM EDT
To: Eryn Hurley <EHurley@naco.org>
Cc: "Danny De Hoog (GVR)" <danny.dehoog@maricopa.gov>
Dear NACIRO members -
Yesterday, NACo submitted formal comments to OMB on its proposed rewrite of 2 CFR Part 200 (Uniform Guidance). The comment letter is attached.
We organized our comments by section so OMB can route each item to the right reviewers, but wanted to flag the overarching concerns we see as highest priority:
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Comment Period: A 412-page rewrite warrants more than 45 days of review. We're asking for at least 60 additional days and a formal state/local consultation process.
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Effective Date: The proposed October 1, 2026 effective date doesn't give counties time to update internal controls, policies, and subaward agreements. We're asking for no earlier than
January 1, 2027, or a phased approach.
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Federalism Assessment: We're asking OMB to withdraw its finding that the rule has no federalism implications and to conduct a formal consultation process under Executive Order 13132.
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Viewpoint Neutrality: This provision extends a viewpoint neutrality condition to county property and events that receive no federal funding at all. We're asking OMB to narrow it to
the specific federally funded activity.
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Termination Standard: We're asking OMB to narrow the proposed "national interest" standard for terminating awards, codify protections for congressionally designated funding, and name
the specific programs exempt from discretionary termination.
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Subrecipient Monitoring and E-Verify: The proposed rule expands monitoring and E-Verify obligations regardless of award size or risk, which would be especially burdensome for rural
counties with limited grants staff. We're asking OMB to scale these requirements to risk.
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SAM.gov <http://sam.gov/> Reliability: The rule increasingly relies on SAM.gov <http://sam.gov/> data as a trigger for monitoring and termination, despite GAO's documented concerns
about its accuracy. We're asking OMB to fix SAM.gov <http://sam.gov/> before making it load-bearing.
We know many of you and your member counties have either or are planning to submit comment by tonight's deadline. Please feel free to use any language from our comment letter and reminder
we have also created a template comment letter <https://link.edgepilot.com/x/7uM3JWwc_5HP5DvBcsoIBv0?u=https://naco.sharefile.com/d-s0922fbe3c7354f3c86dd8dd6cfb53fd1> . As you submit
your comments, please share them with us.
Please don't hesitate to reach out with questions, and thank you as always for your partnership on this.
-Eryn
Eryn Hurley
Chief Government Affairs Officer
National Association of Counties (NACo)
ehurley@naco.org <mailto:ehurley@naco.org>
202.942.4204 (o) | 571.262.9015 (m)
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