OMB Proposes the Biggest Rewrite of the Federal Grant Rulebook Since 2013 — Every Section 330 Grantee Would Have to Run E-Verify; Comments Closed July 13

OMB has proposed a government-wide rewrite of the Uniform Guidance (2 CFR Part 200) — the rulebook every Section 330 grant, subaward, and Single Audit runs on ('Regulation for Federal Financial Assistance,' 91 FR / FR doc 2026-10817, published May 29, 2026, joined by HHS and 49 other agencies). The provision with the sharpest operational edge for health centers: recipients AND subrecipients would be required to enroll in DHS's E-Verify system for employees and contractors working under federal awards, and to report employees found not authorized to work.

The proposal also expands termination and pre-issuance review authority and rewrites the equal-opportunity award terms. Feldesman — the law firm most FQHCs use for Section 330 compliance — confirms the rule reaches 'Ryan White clinics, federally qualified health centers (FQHCs), Indian Health Service facilities, and other 340B grantees,' with partner Steve Kuperberg warning the workforce provisions 'could ultimately affect the delivery of patient care' and senior counsel Jesi Carlson noting E-Verify would be a wholly new compliance obligation for many grantees.

The comment period closed July 13, 2026; OMB is expected to issue a final rule later this year (no effective date is set in the proposed rule). For an FQHC this is an unbudgeted HR and compliance lift — E-Verify enrollment, I-9 workflow changes, and subrecipient flow-down — landing in the same window as the December 31 Community Health Center Fund cliff.