California Workforce Association · Member Action Center

OMB Is Rewriting the Rules for Federal Grants.
California's Workforce System Needs to Weigh In — Now.

OMB's proposed overhaul of the Uniform Guidance (2 CFR Part 200) would restrict conference attendance, association memberships, outreach, and public communication paid with federal funds — and expand federal authority to terminate awards. This page helps your board understand the proposal, submit a public comment, and write to your congressional delegation in under 30 minutes.

1 · Understand the issues 2 · Pick your concerns 3 · Find your delegation 4 · Add local facts 5 · Generate & send
Public comments due Monday, July 13, 2026 · Docket OMB–2026–0034   Rule slated to take effect October 1, 2026

Step 1 · What's happening

A brief guide to the proposed rule

On May 29, 2026, the Office of Management and Budget and more than 30 federal agencies jointly proposed the broadest rewrite of the Uniform Guidance — the government-wide rules for federal grants at 2 CFR Part 200 — since 2014 (“Regulation for Federal Financial Assistance,” 91 Fed. Reg. 32198).

The Uniform Guidance governs how every dollar of WIOA and other federal funding may be spent. Changes reach local workforce boards through a cascade: OMB's rule → the Department of Labor's adoption at 2 CFR Part 2900 → DOL/ETA award terms and conditions → EDD directives → the subaward terms you flow down to every contractor and service provider. Many of the proposed changes apply to all federal awards — including WIOA formula funds — not just competitive grants.

Workforce boards support accountability, transparency, and careful stewardship of public funds; boards already operate under statutory formulas, state monitoring, performance accountability, procurement rules, and the single audit. The concern with this proposal is different: it would add federal pre-approval requirements and undefined restrictions to routine, program-necessary activities — training, memberships, outreach, public communication — and introduce new termination and oversight authorities that make multi-year commitments to participants, employers, and providers harder to sustain.

Why your board's voice matters

OMB must review and respond to substantive public comments before finalizing the rule. Comments close July 13. A requested 45-day extension was denied at a June 30 House oversight hearing, and on July 6 Senate Appropriations Chair Susan Collins (R-ME) asked OMB to extend the comment period by at least 90 days and to withdraw portions of the rule — citing mid-award terminations with no right of appeal, political review displacing merit review, payment burdens on small communities, and the risk that presidential priorities supersede congressional intent. Unless OMB formally extends, July 13 stands: submit as if it will. National groups (NAWB, NAWDP, the National Council of Nonprofits) and peer state associations in Pennsylvania, Illinois, Michigan, Washington, and Oregon have already filed or sent letters. The most effective comments are individualized — a board describing its own numbers, its own providers, and its own communities. Identical form letters carry far less weight in the rulemaking record.

Primary sources: Federal Register notice (2026-10817) · Docket OMB-2026-0034 on regulations.gov. This page is an informational summary of a proposed rule, prepared by the California Workforce Association for its members. It is not legal advice; consult your counsel and fiscal officers.

Step 2 · Choose your issues

Select the provisions your board wants to raise

Check the issues you want included in your comment and letters, and expand any card for a plain-language explanation. The “Core five” shortcut selects the provisions with the most direct day-to-day impact on California boards. Selecting fewer issues and adding your own examples is stronger than selecting everything.

Step 3 · Your delegation

Select your local workforce area

Choose your Local Workforce Development Area to identify the U.S. House members whose districts overlap your area, plus California's two U.S. Senators. Percentages show the share of each district's population living inside your area — a rough guide to how much your board's story is that member's constituent story.

Step 4 · Local facts (this is what makes it persuasive)

Add your board's details

Everything below except signer name is optional, but each field you complete replaces a generic placeholder with your board's reality. Comments grounded in specific local numbers and examples are the ones OMB must engage with.

Before you send

Personalize. These drafts intentionally vary by board and by the issues you select, but you should still edit them — add local examples, cut what doesn't fit. Federal reviewers give less weight to identical template comments (this is also NAWB's guidance). Comments and letters become public records.

Step 5 · Generate & send

Your draft comment & letters

Select your issues and local area above, then click Generate drafts.

Select issues and your local area to enable generation.