Coalition Letter to House Committee on Appropriations on the Office of Management and Budget Grant Rule

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August 31, 2026

Dear Chair Cole and Ranking Member DeLauro:

On behalf of 105 nonprofit, public, and community-based national organizations serving communities in every state, we write you to urge Congress stop the U.S. Office of Management and Budget (OMB) or any implementing agency from implementing its proposed revisions to the Uniform Guidance, or any substantially similar policy. This starts but does not end with passing the Senate-passed continuing resolution pausing implementation until after December 11.

OMB’s proposal represents a sweeping and complex overhaul of federal grantmaking that raises serious concerns. As drafted, the rule would inject substantial uncertainty into federal funding by allowing agencies to withhold, suspend, or terminate grants, as well as change key terms and conditions, including mid-performance. As such, this proposal would expose grantees to significant financial, legal, and operational risks, making it harder to deliver essential services in communities.

The consequences would extend across the country. Every state, local government, nonprofit and federal grant recipient or state and local subgrant recipient, could be harmed by OMB’s proposed rule. The reach and impact would be extraordinary and extremely harmful as grant recipients and downstream contracts and community organizations rely on predictable federal funding to carry out critical functions, from housing and infrastructure to health care, education, disaster response, sustainable food production, and community services. This result would be chaos or stagnation in the project. Projects simply will not be finished in a timely manner if they are completed at all—which would fly in the face of Congressional intent funding these programs.

Independent analysts, including Moody’s Ratings1, have warned that the proposal could weaken the reliability of federal funding commitments and negatively affect credit ratings for state and local governments, increasing borrowing costs and ultimately raising costs for taxpayers. This coupled with the inflationary pressures, slowing economic growth and a desire by Congress to limit domestic discretionary spending impact all Americans.

Two examples of the impact:

• Affordable housing projects already rely on fragile capital stacks that layer HOME and CDBG grants, LIHTC equity, subordinate loans, and philanthropic dollars to close gaps created by below-market rents. When a federal grant in that stack can be terminated mid-stream based on shifting priorities, developers must either rely on more expensive private debt or walk away from deals, leaving sites undeveloped, increasing local housing shortages, and families struggling to access affordable housing.
• Colleges and universities have already seen what happens when federal disease-research grants are cut or delayed: labs closed, graduate and post-doctoral researchers lose jobs, and promising projects on cancer, infectious disease, and chronic illness stall. Thousands fewer federal research grants awarded to institutions in 2025 compared with the prior five-year average. Unpredictable federal support pushes universities to chase short-term, low-risk projects instead of long-horizon studies needed to understand and prevent disease, undermining the very “Gold Standard Science” the proposed rule purports to prioritize.

Given the breadth and significance of these concerns, we urge Congress to act to prevent implementation of this rule or any similar policy.

Please also see a letter from 1,930 state, local, and national groups that was sent to OMB2 about this issue attached to this letter.

Signed,
American Association for the Study of Liver Diseases
American Council on Education
American Educational Research Association
American Geophysical Union American Institute of Architects
American Institute of Biological Sciences
American Meat Science Association
American Psychiatric Association
American Public Transportation Association
American Society for Cell Biology
American Society for Nutrition
American Society of Agronomy
American Society of Hematology
American Society of Nephrology
Americans for the Arts
ASM
Association for Women in Science
Association of American Universities
Association of Art Museum Directors
Association of Collegiate Schools of Architecture (ACSA)
Association of Independent Research Institutes
Association of Population Centers
Association of Schools and Programs of Public Health
Association of University Programs in Health Administration (AUPHA)
Clean Energy Business Network
Coalition for Health Funding
Coalition on Human Needs
Community-Based Public Safety Collective
Council of State Community Development Agencies
Council on Social Work Education
Crop Science Society of America
Digital Promise Global
Donald Danforth Plant Science Center
Dream.Org
EDGE Partners
ED-OCR Alumni Collective
EdTrust
Entomological Society of America
Family Promise, Inc.
Federation of American Scientists
Federation of American Society for Experimental Biology (FASEB)
Geological Society of America
Gerontological Society of America
Grant Professionals Association
HIV Medicine Association
Housing Advisory Group
Inclusiv
Independent Sector
Infectious Diseases Society of America
InnovateEDU
Just Detention International
Just Future Project
Law Enforcement Action Partnership
Lawyers for Good Government
Legal Action Center
Mycological Society of America
National Association of Criminal Defense Lawyers
National Association of Housing and Redevelopment Officials
National Association of Social Workers
National Board for Certified Counselors
National Council of Nonprofits
National Council of State Housing Agencies
National Fair Housing Alliance
National Family Planning & Reproductive Health Association
National Housing Law Project
National Legal Aid & Defender Association
National Low Income Housing Coalition
National Network for Youth
National Network to End Domestic Violence
National Public Health Coalition
National Resource Center on Domestic Violence
National Sustainable Agriculture Coalition
National Urban League
National Women’s Law Center Action Fund
NETWORK Lobby for Catholic Social Justice
Optica
PA Education Association
PHI
Population Association of America
PrEP4All
Public Advocacy for Kids (PAK)
Public Housing Authority Directors Association (PHADA)
reDesignED
Rochdale Capital
Save HIV Funding Campaign
Small Business Technology Council
Society for Healthcare Epidemiology of America
Society for Maternal-Fetal Medicine
Society for Neuroscience
Society for Public Health Education
Society for Scholarly Publishing (SSP)
Soil Science Society of America
Stand Up for Science
Stanton Oaks Tenant Association
Stewards of Affordable Housing for the Future
Susan G. Komen
The Concord Consortium
The National Organization of Minority Architects
The Nonprofit Alliance
The Tech Interactive
Third Way
Unitarian Universalists for Social Justice
Water Environment Federation
Youth First Justice Collaborative
YWCA USA