NHSA Public Comment on Proposed Changes to Federal Financial Assistance
July 13, 2026Today, NHSA submitted to the Office of Management and Budget (OMB) the following public comments on OMB-2026-0034: Regulation for Federal Financial Assistance:
The National Human Services Assembly (NHSA) appreciates the opportunity to provide comments on the Office of Management and Budget’s proposed revisions to the Uniform Guidance governing federal financial assistance.
For more than a century, NHSA has served as a nonpartisan convener of national nonprofit organizations dedicated to improving the health, well-being, and economic mobility of individuals, families, and communities throughout the United States. Our members represent many of the nation’s leading human services organizations and work in partnership with federal, state, and local governments to deliver programs authorized by Congress that touch millions of Americans each year.
We recognize the importance of ensuring that federal financial assistance is administered with accountability, transparency, and responsible stewardship of taxpayer resources. However, after reviewing the proposed revisions, we respectfully encourage OMB to reconsider several provisions that, if implemented as written, could significantly and negatively affect the ability of nonprofit organizations and their public-sector partners to deliver essential human services efficiently and effectively.
Federal grants support an extensive network of community-based services, including workforce development, child welfare, aging services, behavioral health, housing assistance, nutrition programs, domestic violence prevention, disaster recovery, youth development, and services for individuals with disabilities.
Most notably, the proposal would expand agency authority to suspend or terminate discretionary grants after awards have been made if an agency determines that an award no longer advances agency priorities or the national interest. Human services organizations frequently make multi-year commitments based upon approved federal awards, including hiring staff, leasing facilities, entering contracts, and establishing services for vulnerable populations.
The proposal would also allow agencies to modify grant conditions after awards have been accepted. Frequent or substantial changes during the performance period could increase administrative complexity, create financial uncertainty, and reduce organizational capacity to focus on delivering services.
NHSA also encourages OMB to carefully consider provisions related to organizational affiliations and partnerships. Human services organizations routinely collaborate with governments, healthcare providers, educational institutions, businesses, faith-based organizations, and other nonprofits. These partnerships are fundamental to effective service delivery.
We further encourage OMB to provide greater clarity regarding provisions affecting disparate impact analyses and other evaluation methodologies that organizations use to understand community needs, evaluate outcomes, and improve services.
We are likewise concerned about the operational uncertainty surrounding modifications or terminations of grant awards after implementation has begun. Greater transparency and opportunities for administrative review would strengthen confidence in the federal grantmaking process.
The National Human Services Assembly respectfully requests that OMB reconsider those aspects of the proposed rule that could unintentionally reduce funding stability, discourage cross-sector collaboration, increase administrative uncertainty, or limit the ability of nonprofit and public-sector partners to provide essential services to the American people.
We believe there is an opportunity to strengthen the Uniform Guidance while preserving the collaborative relationships, operational flexibility, and accountability that have made federal financial assistance one of the nation’s most effective tools for improving lives and strengthening communities.
Thank you for considering these comments. NHSA welcomes continued dialogue with OMB and other federal partners.
Respectfully,
Victor S. Valentine
Chief Executive Officer
National Human Services Assembly