The Office of Management and Budget’s (OMB) proposed revisions to the Uniform Guidance (2 CFR Part 200), published in the Federal Register on May 29, represent one of the most significant overhauls of federal grants management in years. With a compressed 45-day comment window (closing July 13, 2026) and a target effective date of October 1, 2026, these changes could reshape how federal awards are structured, awarded, and managed beginning in Federal Fiscal Year 2027.

The proposed revisions to the Uniform Guidance signal a fundamental shift in how 2 CFR Part 200 is positioned and enforced across the federal government. Most notably, OMB is moving away from framing the Uniform Guidance as “guidance” and instead solidifying it as the Uniform Grants Regulations using the current formal rulemaking process. For recipients, this means compliance expectations will become more standardized and less flexible, as the rule is elevated to a single, government-wide regulatory framework for all new awards beginning in FY 2027. However, legal challenges to this seem likely.

At the same time, the proposal significantly expands oversight throughout the entire grant lifecycle, introducing greater scrutiny both before and after awards are made. On the front end, enhanced merit review processes and expanded risk assessments will evaluate not just technical merit, but also organizational integrity, affiliations, and alignment with federal priorities. On the back end, recipients will face tighter controls over subrecipient monitoring, cash management, and documentation, along with new requirements such as E-Verify participation and more detailed payment justifications. Perhaps most notably, agencies are granted broad discretionary authority to terminate discretionary awards if they no longer align with program goals or evolving priorities, with limited avenues for appeal.

Finally, the revisions more explicitly tie the use of federal funds to defined policy priorities and restrictions, expanding the scope of what constitutes compliant program activity. New provisions address areas such as foreign collaborations, use of funds in connection with administrative priorities, free speech considerations, and broader statutory policy requirements, while also adjusting procurement standards and cost principles. These changes require recipients to think beyond financial stewardship and consider whether program design, partnerships, and operations align with federally established policy boundaries.

With more than 37,000 comments submitted as of late June 2026 and growing fast, along with the potential for litigation, the final rule may evolve and most likely be delayed. Until OMB issues a final rule sometime in late summer, these proposed changes remain tentative. However, recipients and subrecipients should stay informed and be prepared to make changes once an updated Uniform Guidance is issued.

Missed NGMA’s live webinar on the proposed updates on June 17, 2026? Visit Grants Management Academy to view the recording.

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Subrecipient partnerships are essential to advancing research and delivering impactful programs, but they also introduce risk. As emphasized in NGMA’s May 2026 webinar, You’re Still on the Hook: The Real Costs of Weak Subaward Oversight, federal oversight expectations are clear: While recipients may delegate work, they cannot delegate responsibility.

Drawing on federal regulations, audit findings, and real-world examples of why oversight falls short, the presentation provided practical strategies for organizations to help protect their funding, reputation, and program success.

Three takeaways from the presentation:

1. Accountability Always Stays with the Prime Recipient

The most important concept in subrecipient management is also the simplest: Ultimate accountability remains with the prime recipient.

Even when a subrecipient is responsible for carrying out a portion of the award, the prime recipient retains full responsibility for all financial and programmatic outcomes. When compliance issues arise—whether due to unsupported costs, mismanagement, or failure to meet program goals—it is the prime recipient that must respond, resolve the issue, and potentially repay disallowed costs.

This dynamic fundamentally shapes how oversight should be approached. Subrecipient monitoring is not simply a compliance exercise. It is a risk management function designed to protect the institution, its funding, and its reputation.

2. Weak Oversight Has Real Financial and Programmatic Consequences

Subrecipient oversight failures are not theoretical; they are consistently identified in audit findings across federal programs. Recent audit reports issued by federal oversight bodies highlight common breakdowns, including failure to conduct risk assessments, inadequate review of subrecipient audit reports, and insufficient monitoring practices, and included findings with:

• Unallowable and unsupported costs resulting in substantial questioned costs
• Inaccurate classification of subawards versus contracts, leading to missed compliance requirements
• Inadequate monitoring that undermines program performance and accountability

Weak oversight can also result in missed program goals, reduced transparency, and increased scrutiny from funding agencies—ultimately putting future funding at risk.

3. Effective Oversight Requires a Proactive, Risk-Based Approach

Strong subrecipient oversight does not happen by accident. It requires intentional, documented, and risk-based processes across the lifecycle of the subaward.

Effective practices begin before the subaward is issued, with meaningful due diligence that evaluates a subrecipient’s financial systems, internal controls, and past audit results. Importantly, this process should go beyond collecting information to verifying that key controls actually exist and function as expected.

Once a subaward is established, oversight should include:

• Tailored terms and reporting requirements aligned to identified risk
• Ongoing monitoring of financial and programmatic performance
• Regular review of audit results and follow-up on any findings
• Clear documentation of monitoring activities and corrective actions

Critically, effective oversight is not one-size-fits-all. Federal guidance emphasizes the importance of adjusting monitoring activities based on the level of risk presented by each subrecipient. High-risk subrecipients require more intensive oversight, while lower-risk partners may warrant a lighter approach—but in all cases, monitoring must be purposeful and documented.

Final Thought

Subrecipient partnerships are critical to delivering federal programs, but they require thoughtful oversight to manage the risks they introduce. By understanding the accountability framework, recognizing the real consequences of weak oversight, and implementing proactive, risk-based practices, organizations can better safeguard federal funds and strengthen program outcomes.

At the end of the day, regardless of how experienced your partners may be or how strong your relationships are, one principle remains constant: You’re still on the hook.

Missed the live presentation? This and all other recorded webinars are available in Grants Management Academy, NGMA’s education portal. (Member login required)

As the American Rescue Plan Act (ARPA) State and Local Fiscal Recovery Funds (SLFRF) program moves into closeout phase, it’s clear that closeout success is determined long before the final report is submitted.

NGMA and Hagerty Consulting partnered on a webinar presentation to help ensure a successful SLFRF closeout. Below are key takeaways from the presentation for recipients and subrecipients navigating the SLFRF closing stages. While this information focuses on SLFRF, the principles shared are broadly applicable for federal grant closeout.

1. Spending the Money is Not the Finish Line

Awareness of the expenditure deadline (and the specific instances of variation from that deadline) is essential but is only the starting point of compliance, not the end. Treasury’s closeout process confirms that funds are spent and reported, but audits, data reviews and follow-up inquiries continue long after a closeout certification is submitted. SLFRF closeout triggers a five-year record retention period, during which Treasury, the Government Accountability Office (GAO), or the Treasury Inspector General may request records. Organizations that “finish strong” are those that can clearly track where every dollar went, reconcile reported data back to their general ledger, and explain why each cost was eligible. In short, reporting done does not mean compliance done.

2. Audit Readiness Comes Down to Systems, Not Intentions

Let’s highlight a “48-hour test,” which is: If an auditor requested complete SLFRF documentation with two days’ notice after the person who organized it was no longer with the organization, could your organization deliver it? Many audit findings are not caused by bad actors or misuse of funds, but by fragmented documentation, informal practices or controls that existed on paper but not in daily operations. Audit-ready organizations have standardized documentation systems, clear ownership of compliance responsibilities and controls that operate in real time rather than at closeout. Additionally, if justification, approvals and reconciliations live only in email threads or people’s heads, the file is not audit‑ready, regardless of how confidently staff remember the decisions.

3. The Real Outcome of Closeout is Institutional Capacity

SLFRF closeout is not just about SLFRF. The controls, governance, reconciliation practices, and documentation systems required to close this award cleanly are the same ones that auditors will expect on every future federal grant. Organizations that treat closeout as a one‑time cleanup exercise miss the opportunity to convert years of effort into durable grants management capacity and often repeat the same findings later under a new program.

Bottom line? Finishing strong requires planning ahead. Organizations that actively manage time risk, build documentation for external review, and treat closeout as capacity‑building, will exit SLFRF not just compliant, but stronger than when they entered.

Missed the webinar? This and all other recorded webinars are available in Grants Management Academy, NGMA’s education portal. (Member login required)

Nicole Ward and Benjamin Shay are senior managing associates with Hagerty Consulting, a firm that partners with clients to safeguard their people, operations and communities before, during, and after disasters.

The U.S. Government Accountability Office (GAO) has estimated that, for fiscal years 2018 through 2022, the U.S. government’s total direct annual financial losses will range from $233 billion to $521 billion. ^[1] This staggering amount encompasses various types of fraud, including grants.

Primary Stage of Fraud Occurrence

The majority of fraudulent activities transpire after the award is granted, specifically during the active award phase (also known as post-award), when the award has been conferred, work is in progress, and financial transactions are ongoing. Granting agencies utilize a range of procedures and tools to identify fraud during this post-award period; however, these measures are predominantly reactive rather than proactive.

Lack of Structured Fraud Data Compilation

Given the wide variety of grant fraud, agencies may encounter different types of fraud across grant programs. Some of the common categories of fraud encountered are:

• Program fraud
• Procurement fraud
• Misallocation of funds
• Nepotism

Diverse, disconnected, unstructured data on fraud originating from multiple sources and in incompatible formats is lost without a standardized storage and reporting framework. The type and nature of the fraud, along with other associated details, aren’t captured in a format that can be used to perform future checks against grantees.

Closeout Evaluation: Data with a Strong Purpose

Closeout evaluation isn’t merely a report or a formality to be completed. It is a powerful tool that captures comprehensive feedback on the grant. When used as intended within the specified timelines, it serves as a one-stop shop for highlighting the grantee’s operational, financial, and behavioral performance on the grant, which ultimately helps prevent future grant fraud. By capturing potential red flags in a structured format across these categories, the evaluation clearly documents deviations from standard grant management procedures. The recommendations below are not exhaustive, but are intended to guide practical, detailed action for documenting abuse, fraud, or waste concerns in a structured, consolidated format.

• Financial Indicators:
  • Spending arrangement (especially at award end)
  • Reallocation of funds without conforming to procedures
  • Frequent budget revisions
• Operational Indicators:
  • Poor and/or missing documentation, patterns indicating false deliverables
    • These two forms of fraud illustrate tactics used to obtain willful gains
  • Deviations in reporting requirements and monitoring results
  • Unverifiable/false reporting on outcomes
    • In the case of “Feeding Our Future,” multiple entities were created to open Federal Child Nutrition Program sites throughout Minnesota, falsely claiming to serve thousands of children within days or weeks of formation
  • Behavioral Indicators:
    • Repeated late submissions, multiple resubmissions, and corrections of documents
    • Irregular conduct or inconsistencies observed on a consistent basis
    • Unresolved issues or concerns with overall performance

A grant applicant’s past performance can be evaluated either manually or using newer technologies, such as Artificial Intelligence (AI). A standardized format leveraged by AI can perform a quantitative risk analysis. It can generate risk scores for each grantee based on its analysis of the evaluation categories.

To conclude, well-structured, properly completed closeout evaluations not only facilitates the closure process but also serve as vital input for assessing the grantee in future grant applications. Using the grantee’s Unique Entity ID (UEI), agencies can review previous closeout evaluations and generate a summary of past performance and related metrics to evaluate the grantee’s future proposals. This creates a complete cycle in which closeout evaluations inform the risk assessment during the pre-award phase.

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Bharadwaj (B) Raghuram, PMP, CSM, is a program manager at I&I Software Inc. with more than 20 years of experience in the private and public sectors. He currently advises state and local governments, with a focus on program and technology transformations, particularly the modernization of grant initiatives. His current work emphasizes improving grant programs through AI-powered fraud detection and prevention. He may be reached at bharadwajraghuram7@gmail.com
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[1] Fraud Risk Management: 2018-2022 Data Show Federal Government Loses an Estimated $233 Billion to $521 Billion Annually to Fraud, Based on Various Risk Environments – GAO-24-105833 – Published: Apr 16, 2024. Publicly Released: Apr 16, 2024, 2.

Joey DeSantis and William Treanor of EY were a part of NGMA’s monthly webinar series. In their presentation, How to Get Sub-Awardees to Understand and Follow the Rules: A Lifecycle Approach to Uniform Guidance Compliance, they offered practical strategies for ensuring sub-awardees understand and comply with federal, state and organizational regulations. This article summarizes key takeaways from their presentation.

Access the recording through Grants Management Academy, NGMA’s education portal.

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Over the last year, grant professionals have been operating in a more uncertain environment than usual. Funding pauses, program terminations, legal challenges, and updated federal guidance have created real pressure for both prime recipients and their sub-awardees. In this climate, expectations around sub-awardee oversight have continued to increase, even as capacity remains strained.

Based on recent discussions with grant professionals, three themes consistently stand out when it comes to strengthening sub-awardee oversight in today’s environment.

1. Sub-Awardee Oversight Starts Earlier Than Many Organizations Think

Many compliance issues traced back to sub-awardees do not originate during project execution. They begin much earlier, often during pre-award or onboarding, when expectations are not clearly communicated or risks are not fully assessed.

Recent policy changes and audit findings reinforce the importance of treating oversight as a lifecycle responsibility. Risk assessments, eligibility verification, flow-down of requirements, and documentation of expectations all need to happen before funds are released. Waiting until reporting problems or audit findings surface makes issues harder—and more expensive—to correct.

Organizations that invest time upfront tend to spend less time later responding to findings, negotiating corrective actions, or repairing strained relationships with sub-awardees.

2. Many Compliance Issues Reflect Capacity Gaps, Not Resistance

In practice, most sub-awardee challenges are not caused by a lack of willingness to comply. They are caused by limited staffing, competing priorities, and unfamiliarity with federal requirements, especially among smaller organizations or first-time recipients.

When oversight is framed purely as enforcement, it can lead to pushback, delays, or breakdowns in communication. When it is paired with clear guidance, onboarding support, and targeted technical assistance, outcomes tend to improve for everyone involved.

Grant managers frequently see better results when they focus on helping sub-awardees understand what is expected, why it matters, and how to meet those expectations within their existing capacity.

3. Risk-Based Monitoring Is More Effective Than One-Size-Fits-All Oversight

Not all sub-awardees pose the same level of risk, and monitoring approaches should reflect that reality. A risk-based framework allows organizations to focus attention where it is most needed, rather than applying the same level of scrutiny across the board.

Effective monitoring programs typically include regular desk reviews, periodic site visits for higher-risk partners, follow-up on audit findings, and clear documentation throughout the grant period. Just as important, they build in opportunities to adjust monitoring as circumstances change.

This kind of structured approach helps organizations identify issues earlier, use oversight resources more efficiently, and demonstrate due diligence if questions arise later.

Looking Ahead

Sub-awardee oversight is becoming more visible, more scrutinized, and more consequential. Federal agencies, auditors, and the public all expect stronger accountability across the full chain of grant funding.

For grants professionals, the goal is not simply to avoid findings. It is to create oversight practices that support compliance while allowing programs to operate effectively. Organizations that take a proactive, risk-informed approach are better positioned to meet that challenge—especially in an environment where uncertainty is likely to continue.

For the National Grants Management Association (NGMA) and the Association of Government Accountants (AGA).

On August 7, 2025, the White House issued Executive Order 14117, Improving Oversight of Federal Grantmaking, which introduces sweeping reforms to how federal grants are awarded, reviewed, and monitored. This article outlines the key provisions of the order, explores its implications for grants and financial professionals, and highlights the critical role of professional associations such as the National Grants Management Association (NGMA) and the Association of Government Accountants (AGA) in navigating this transition.

Key Provisions of the Executive Order

The Executive Order directs federal agencies to take several concrete steps to improve the integrity and impact of grantmaking. Each agency must now appoint a senior official responsible for reviewing new discretionary grant announcements to ensure they align with the Administration’s national priorities. This added layer of oversight is intended to bring greater consistency and strategic focus to funding decisions. In addition, federal agencies are required to implement more rigorous and transparent review processes. While this promotes fairness and clarity for applicants, it may also result in delays or compressed timelines for funding announcements and awards.

Additional key provisions include directing the Office of Management and Budget (OMB) to revise the Uniform Guidance to simplify application requirements. This simplification is intended to improve access for under-resourced communities that have historically faced barriers to apply. Further provisions include requiring agencies to update grant agreements to include termination provisions, allowing funding to be discontinued if projects no longer align with federal goals. While this introduces flexibility for agencies, it also creates uncertainty for recipients. Another provision directs agencies to require specific authorization and justification for fund drawdowns, shifting the burden of accountability to the front end of the funding process. This change is intended to prevent misuse of funds before it occurs, rather than relying solely on post-award audits.

Overall, this Executive Order signals increased scrutiny of programs perceived as ideologically driven or lacking in measurable impact. Grants professionals should be prepared to defend the relevance, rigor, and replicability of their proposed work.

Implications for Grants and Financial Management

These reforms are designed to enhance transparency, accountability, and strategic alignment in federal grantmaking. For professionals in grants and financial oversight roles, the implications are wide-ranging.

Applicants can expect clearer guidelines and more predictable review processes, which will help them better understand funding priorities and compliance expectations. However, the increased scrutiny may also mean that applications and drawdown requests will be evaluated more rigorously, particularly in terms of alignment with national objectives and demonstrable outcomes.

While the revisions to the Uniform Guidance are intended to streamline the application process, the transition period may introduce delays as agencies adjust to new procedures. The inclusion of termination provisions in grant agreements introduces a new level of flexibility for federal agencies—but also requires recipients to remain agile and responsive to shifting federal priorities.

Importantly, the Executive Order encourages agencies to broaden their recipient pools, with a focus on including first-time applicants. This could increase competition but also opens the door to new partnerships and innovative approaches to program delivery.

Strategic Recommendations for Grant and Financial Professionals

To navigate this evolving landscape effectively, grants and financial professionals should adopt a proactive and strategic approach. It is critical to start preparing in advance of funding announcements. Maintaining a portfolio of grant-ready projects—complete with impact data, performance metrics, and potential partners—can significantly streamline the application process. It’s also essential to keep your SAM.gov registration current, renewing it well before expiration which can avoid any potential administrative delays.

When crafting funding proposals, ensure that your narratives are tightly aligned with both the specific funding opportunity and broader administration priorities. Use the scoring criteria provided in the notice to guide your content, and make sure your narrative clearly supports measurable outcomes and aligns to the budgeted activities. Proposals should be written in plain language, avoiding jargon and emphasizing clarity and accessibility—reflecting the federal government’s renewed focus on readability. It is critical to stay alert to changes in funding opportunity announcements, even for recurring programs. Treat each opportunity as new and carefully review the language and structure to ensure your application aligns with updated priorities.

Indirect cost rates are another area to closely watch. Lower rates are increasingly preferred, and capped in many cases, so it is imperative to work with your grants or finance office to understand your current rate and explore options for strategically reducing the rate. Ensure directly allocable costs are not in your cost pool out of convenience.

Accountability of performance outcomes is more important than ever. Applications should include measurable benchmarks for success and demonstrate a commitment to evidence-based practices. Citing open science principles, replication studies, or third-party validations can strengthen your case and align with federal expectations. Post-award compliance will no longer rely solely on financial progress reporting. Financial and programmatic reporting systems must be strengthened to support real-time performance tracking. Federal agencies will expect more than just financial compliance-they will want to see evidence of impact.

Finally, consider expanding your network of partners. The Executive Order encourages broader participation in federal grantmaking, which may increase competition but also presents opportunities for new partnerships and innovation. Collaborating with new or non-traditional organizations may enhance your performance outcomes and increase your competitiveness in a broader recipient pool.

The Value of Professional Engagement: NGMA and AGA

In today’s rapidly evolving grants and financial management landscape, staying connected to professional associations is not just beneficial, it’s essential. Two organizations stand out for their leadership, resources, and community: the National Grants Management Association (NGMA) and the Association of Government Accountants (AGA).

Since 1978, NGMA has served as a cornerstone for grants professionals across all sectors—federal, state, local, tribal, nonprofit, higher education, and the private sector. NGMA provides full lifecycle grants management training, professional certification through the Certified Grants Management Specialist (CGMS) credential, and continuing education opportunities. Members benefit from access to the Grants Management Body of Knowledge (GMBoK), a robust calendar of webinars and sector meetings, and a vibrant community forum that fosters peer learning and support. NGMA is committed to promoting best practices and professional excellence in grants management, helping members stay ahead of regulatory changes and funding trends

Meanwhile, AGA, founded in 1950, is the leading association for government financial management professionals. With a mission to advance accountability, transparency, and performance in government, AGA empowers its members through training, certification, and leadership development. The Certified Government Financial Manager (CGFM) credential is a hallmark of professional excellence in public sector finance. AGA also plays a key role in shaping policy and promoting ethical standards through its code of ethics and strategic initiatives. Members gain access to a national network of professionals, thought leadership, and tools that support career growth and good government practices

Together, NGMA and AGA offer a powerful combination of expertise and community. Engaging with both organizations allows professionals to bridge the worlds of grants and financial management- ensuring compliance, maximizing impact, and advancing their careers. Whether you’re navigating Uniform Guidance, managing indirect costs, or leading performance audits, these associations provide the knowledge, tools, and support to succeed.

Conclusion: A Joint Call to Action

This Executive Order represents more than a policy update—it’s a call to action for grants and financial professionals to lead with strategy, integrity, and adaptability. By aligning practices with the new federal framework, professionals can continue to secure critical funding, support community priorities, and contribute to a more transparent and effective federal grantmaking system.

Connecting to both NGMA and AGA will empower you to stay ahead of policy shifts, share best practices, and uphold the highest standards in grants and financial management as the federal landscape evolves. Leveraging the collective knowledge and support of both organizations will ensure you can navigate these federal changes with confidence—ensuring that public funds are administered effectively, transparently, and in service of the greater good.

Stacie Massey is Deputy Director of Grants and Financial Reporting at the Ohio Office of Budget and Management. Stacie has over 25 years of public sector experience in previous roles at the Ohio Public Employees Retirement System, Ohio Auditor of State, Ohio Department of Public Safety, and Ohio Emergency Management Agency.

Effective October 1, 2025, the U.S. Department of Health and Human Services (HHS) will officially retire its 45 CFR Part 75 framework. Going forward, HHS will adopt the 2 CFR 200 Uniform Guidance in full, with agency-specific provisions codified under 2 CFR Part 300.

For many organizations, this may look like a simple regulatory update. In reality, the changes bring new requirements that will affect day-to-day operations, financial oversight, and long-term planning. Smaller organizations, in particular, may feel the weight of these revisions, as lean teams and limited infrastructure make it harder to adapt quickly.
At the same time, the shift offers an opportunity to strengthen internal systems and build lasting capacity.

Key Changes

1.  Regulatory Realignment

HHS has now aligned itself fully with the 2 CFR 200 framework, supported by a new set of rules under Part 300. Grantees will need to update internal policies, grant manuals, and related documentation to reflect the new structure. While streamlining this framework is intended to create consistency across agencies, it requires focused administrative work to ensure nothing is overlooked.

2.  Lower Budget Revision Thresholds

The threshold for prior approval of budget revisions has dropped from 25% of total direct costs to 10% of the total approved budget, including cost share. As a result, grantees should expect to seek approvals more often and will need to monitor budgets more closely to avoid delays.

3.  Expanded Civil Rights Certifications

Grantees must now certify compliance with Title IX and other civil rights requirements across all awards, not just those where the language appears in the Notice of Award. This change increases accountability and underscores the importance of integrating civil rights compliance into every program.

4.  Stricter No-Cost Extension Rules


Requests for no-cost extensions must be submitted at least 10 days before the end of the budget period in the final year of performance. Previously treated more flexibly, this deadline is now a firm requirement, and late requests will likely be denied. Careful planning during close-out will be essential to avoid leaving funds unspent.

5.  Termination for Convenience


HHS now reserves the right to terminate awards for its own convenience, with no appeal available to grantees. This provision creates real financial risk, particularly for smaller organizations with limited reserves or few funding sources. Building contingency plans will be critical.

Preparing for the Transition

Adapting to these changes will require preparation, but there are practical steps smaller organizations can take:

• Review policies and practices. Conduct a gap analysis to identify where current systems do not meet the new requirements.
• Update internal documents. Manuals, standard operating procedures, and templates should reflect new rules and thresholds.
• Invest in training. Staff and board members should understand both the changes and their roles in maintaining compliance.
• Strengthen documentation. Consistent, well-organized records of financial activity, performance data, and civil rights compliance will help ensure readiness for audits.
• Communicate with funders. Proactive dialogue with funding agencies can clarify expectations and provide room for flexibility during the transition.

Looking Ahead

The new guidance is more than a compliance exercise. For smaller organizations, it is an opportunity to create stronger, more resilient systems that will support growth and stability over time. By approaching the revisions with intention and preparation, organizations can not only remain in compliance but also position themselves to thrive in a funding environment where accountability and competition continue to grow.

Those who invest in building strong compliance infrastructure now will be better equipped to deliver programs effectively, serve their communities with confidence, and sustain their work well into the future.

D’Laun Oubre, MBA is a seasoned grants management leader with nearly two decades of experience in accounting, post-award compliance, and federal funding oversight. As Director of Grants Management Services at Kim Joyce & Associates, she has stewarded $30 million+ in funding while mentoring teams, embedding internal controls, and shaping best practices in federal grants compliance.

She’s an active member of the National Grants Management Association and a trusted voice in the field of federal grants compliance.

The August 2025 Grants Management webinar, Funding Interrupted: Navigating Grant Terminations in a Shifting Federal Landscape, addressed one of the most pressing issues in today’s federal funding environment: the increasing frequency of grant terminations and the evolving rules that govern them. The session provided a detailed overview of the regulatory requirements under the Uniform Guidance, recent policy changes, and strategies for grantees to remain resilient amid uncertainty.

Understanding Federal Grant Terminations

At the foundation of the discussion was an overview of how federal grants may be terminated and the regulations around grant terminations under 2 CFR 200.340-345. Grants may end in three primary ways:

• For Cause – A funding agency unilaterally ends a grant due to noncompliance.
• By Mutual Agreement – Both parties consent to end the grant under agreed terms.
• For Convenience – A federal agency discontinues the award due to shifting priorities or funding changes.

Termination provisions must be clearly defined in grant agreements and passed down to subrecipients and contractors. Grantees also carry specific responsibilities during and after termination, including closeout procedures, returning unobligated funds, and managing property and records. Importantly, certain costs, such as personnel termination expenses or unrecoverable activity costs, may be allowable under 2 CFR 200.472 if they are reasonable and not due to negligence.

Recent Policy Shifts Impacting Terminations

The federal landscape has shifted considerably in 2025, reshaping how terminations are handled and what grantees must prepare for. Two key developments are:

1. The One Big Beautiful Bill Act (OBBBA)
   This legislation introduced faster termination timelines, expanded discretionary authority for agencies, and added new reporting and justification requirements. While the provisions increase transparency and oversight, they also require grantees to adapt quickly when awards are reduced or discontinued. OBBBA also established enhanced protections for grantees, including clearer appeals pathways and stronger expectations for contingency planning.
2. Executive Order on Improving Oversight of Federal Grantmaking
   Issued on August 7, 2025, this Executive Order (EO) requires annual reviews of discretionary awards, limits the use of these funds for administrative costs, and directs OMB to update the Uniform Guidance. Notably, the EO allows agencies to terminate discretionary grants “for convenience” if they no longer align with national priorities, signaling greater volatility for many programs. Agencies are now encouraged to incorporate termination clauses into current and future agreements, making it even more important for recipients to read the fine print of their awards.

Strategies for Navigating Terminations

Preparedness and agility are key in managing grant terminations. Grantees are advised to:

• Closely monitor federal funding notices and guidance for early signs of changing priorities.
• Maintain thorough documentation of policies, expenditures, and performance reports to support compliance and potential appeals.
• Establish internal communication protocols to ensure quick, coordinated responses to termination notices.
• Build risk mitigation and contingency plans into every program, including diversifying funding sources and strengthening relationships with state and local partners.

Additionally, communication is key. Upon receiving a termination notice, grantees should immediately clarify scope and requirements with the awarding agency, notify all subrecipients and contractors, and document every interaction and cost incurred. Appeals processes differ by agency, but preserving rights through timely documentation and legal consultation is essential.

Key Takeaways

1. Federal policy changes have expanded agency authority to terminate grants more quickly and for broader reasons, requiring grantees to stay alert to shifting political and budget priorities.
2. Thorough documentation, clear communication, and contingency planning are critical tools for navigating unexpected terminations and safeguarding allowable costs.
3. Grantees must proactively prepare by building risk mitigation protocols, monitoring federal guidance, and understanding appeals processes to remain resilient in today’s volatile funding environment.

In the current federal climate, we see that grant terminations are no longer rare exceptions but a growing feature of the federal funding landscape. With new legislation and executive directives reshaping the rules, grantees face greater uncertainty, but also greater opportunity to strengthen internal systems, ensure compliance, and build resilience. By focusing on preparedness, documentation, and communication, organizations can position themselves to navigate terminations effectively and continue advancing their missions despite federal shifts.

Career burnout is very real in grants management. With huge responsibilities, strict deadlines, and the constant pressure of aligning programs with funder expectations, many of us hit the wall sooner than we’d like to admit. The advice we usually hear? Step away from your work: take a walk, meditate, go on vacation, pick up a hobby, or drink more water. These are all wonderful and necessary, but if you’ve tried them, you know they often provide only temporary relief.

So what do you do when the vacation glow fades and the inbox is still overflowing? One answer may be to stop stepping away from your career—and instead start leaning into it. Here are a few “outside the box” approaches I’ve found can truly help rekindle passion and keep burnout from becoming the defining chapter of your professional story.

1. Rediscover Why You Fell in Love with the Work



When was the last time you paused to ask yourself: Why did I choose this field? Burnout often clouds that original spark. Reconnecting with your “why” is more than a pep talk—it’s about intentionally revisiting the parts of your career that once excited you.

Try journaling about what first drew you to grants management. Was it the satisfaction of stewarding dollars to nonprofits doing critical work? The intellectual puzzle of compliance and regulations? The joy of helping mission-driven organizations succeed? By pinpointing your entry point, you can often find ways to reignite that same energy in your current work.

2. Expand Your Perspective Beyond Your Usual Seat



One of the most powerful burnout antidotes is stepping into another vantage point—while staying within your field. For me, the turning point came after leaving my job having years of experience as a federal grants management specialist. I knew every clause of 2 CFR 200, but I had never experienced the other side: what it feels like to be a nonprofit organization struggling to win and manage a grant.

Switching gears to consulting has been eye-opening. Suddenly, I wasn’t just enforcing compliance rules; I was helping organizations tell their stories, build strategies, and compete for funding. This role reversal didn’t just expand my expertise—it gave me new respect and energy for the work.

You don’t need to change careers to try this. Volunteer to review grants for a local foundation. Shadow a program officer. Teach a grant writing workshop at a community college. These fresh perspectives will challenge you, sharpen your skills, and remind you why your work matters.

3. Turn Learning into a Hobby



Self-care doesn’t always have to mean leaving your work behind. What if your “hobby” could be a form of professional play? Take an online course in a skill adjacent to your role, such as nonprofit storytelling, data visualization, or even AI tools for grants management. Start a blog where you translate the complexity of grants into plain English. Mentor a student who’s curious about entering the field.

By channeling curiosity into side projects, you trick your brain into seeing your career not as an endless grind, but as a living subject you get to explore on your own terms. It’s less about “work” and more about intellectual joy.

4. Build Micro-Moments of Mastery



Burnout often comes from feeling like no matter how much you do, you’re always behind. One antidote? Design tiny, achievable wins. Instead of putting “Award five grants today” on your list, try breaking it into micro-goals like “Review these statements of work today” or “Review submitted budget proposals by noon.”

Celebrate these small victories. Not with balloons or cupcakes (though those are nice) but with a simple acknowledgment: I moved the needle forward today. Over time, this habit rewires your relationship with deadlines, replacing overwhelm with steady progress.

5. Create Your Own “Career Ecosystem”



Finally, remember you are not a single role—you are an ecosystem. Maybe you are a grants manager, but you’re also a writer, mentor, strategist, or teacher. Burnout often happens when we let one role swallow all the others.

So, diversify. Build space for the other parts of your professional identity to thrive. For example, you might dedicate one hour a week to writing an article on best practices, or schedule quarterly meetups with peers to exchange fresh ideas. These outlets give oxygen to your ecosystem, making the whole system healthier and more sustainable.

Closing Thought



Managing burnout isn’t about escaping your work—it’s about reframing your relationship with it. By leaning in, shifting perspectives, and creating opportunities for curiosity and mastery, you can transform burnout from a dead end into a bridge toward deeper fulfillment.

The next time you feel bogged down, instead of asking, “How can I get away from this?” try asking, “What fresh angle can I discover within this?” You might just find that the spark you thought was gone was only waiting for you to see your career from a new light.