Late last week, the White House Office of Management and Budget (OMB) published a proposed rule, "Regulation for Federal Financial Assistance," that would revise the Uniform Guidance governing federal grants (2 CFR Part 200). Several proposed changes would affect how grant recipients participate in association activities.

 A couple of areas stand out for the association community:

• Membership dues: Membership and subscription costs would be allowable only if necessary to fulfill the award requirements and approved in advance by the federal agency. Costs for subscriptions to business, professional, academic, and technical periodicals would no longer be allowable. Costs of membership in organizations whose primary purpose is issue advocacy would not be allowable, in addition to the current ban on memberships in organizations whose primary purpose is lobbying.
• Conferences: Costs for attending conferences would only be allowable if participation in the conference is expressly approved by the relevant federal agency and included in the terms and conditions of the federal grant.

ASAE is conducting a full review of the proposed rule and intends to submit public comments. We will follow up with members on specific opportunities to participate in this advocacy effort.

 Comments are due to OMB by July 13, 2026.

 We will share more as our analysis develops.

For questions, contact Kyle Hayes, Senior Director of Public Policy, at [email protected].

Thank you,

Mary Kate Cunningham, CAE

Chief Public Policy and Governance Officer, ASAE