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How Federally Funded Organizations Should Prepare for OMB Proposed Overhaul of Grants Oversight, DEI Bans, Easier Terminations

By John S. Moran, Sarah Wake, Edwin O. Childs, Jack White, Jason M. Vespoli, John Sullivan & Sophie Marsh on June 8, 2026
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As part of the Trump administration’s efforts to implement a broad range of executive orders targeting diversity programs and other policy priorities in federal grantmaking, OMB published a proposed rule on May 29, 2026, that would substantially revise the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (2 C.F.R. part 200). Organizations that receive federal funds should start considering a host of actions to prepare for these changes if implemented, including determining whether any current programs and policies that exhibit DEI characteristics should continue and, if so, documenting their business rationale and legal basis. Organizations will also be required to ensure that they, subrecipients, and downstream contractors update and maintain policies that follow the new requirements, especially as agencies may have broader powers to terminate funding deemed no longer to advance “the national interest.” Finally, organizations should consider submitting public comments to alert the government of provisions that would benefit from more clarity or may cause undue burdens.

Read on to learn more about the background and implementation of these policies.

Photo of John S. Moran John S. Moran

John Moran is a member of the firm’s nationally recognized Government Investigations and White Collar Litigation department. A former senior official at the U.S. Department of Justice (DOJ) and the White House and an experienced litigator and counselor, John draws on his broad…

John Moran is a member of the firm’s nationally recognized Government Investigations and White Collar Litigation department. A former senior official at the U.S. Department of Justice (DOJ) and the White House and an experienced litigator and counselor, John draws on his broad experience from private practice and government service to advise and represent clients in government enforcement, congressional investigations, high-stakes civil disputes, and regulatory litigation. He also serves as co-chair of the firm’s Congressional Investigations practice, representing both companies and individuals in congressional investigations and hearings and is a member of the firm’s Appeals & Issues group.

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Photo of Sarah Wake Sarah Wake

Sarah, co-leader of the firm’s Higher Education Practice Group and Sports Industry Team, knows firsthand the complex legal and compliance challenges that corporations and educational institutions face, having served almost a decade as in-house counsel and a senior leader at top universities.

A…

Sarah, co-leader of the firm’s Higher Education Practice Group and Sports Industry Team, knows firsthand the complex legal and compliance challenges that corporations and educational institutions face, having served almost a decade as in-house counsel and a senior leader at top universities.

A skilled litigator, Sarah represents a wide range of higher education clients — including top research institutions, liberal arts colleges and institutions with Division I athletics programs  — on issues related to faculty tenure and promotion; student and employee unionization; discrimination and harassment policy, investigations and hearings; Title IX compliance; athletics (including coaching contracts, hazing, NCAA compliance and NIL); admissions; student conduct; diversity and inclusion; the Clery Act; the Family Educational Rights and Privacy Act; and physical and digital accessibility.

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Photo of Edwin O. Childs Edwin O. Childs

As a leader of the firm’s Defense, National Security and Government Contracting industry team, Ned Childs is a government contract and investigations and enforcement attorney who represents companies across a wide range of sectors, including the defense, services, technology, and aerospace industries. His…

As a leader of the firm’s Defense, National Security and Government Contracting industry team, Ned Childs is a government contract and investigations and enforcement attorney who represents companies across a wide range of sectors, including the defense, services, technology, and aerospace industries. His practice, spanning more than a decade in Washington, encompasses a broad array of legal services, including government contract investigations, disclosures, and regulatory enforcement actions; bid protests and government contract disputes; government contract counseling; export licensing and enforcement; prime contractor-subcontractor disputes; corporate ownership and acquisition issues; and election law investigations and enforcement matters.

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Photo of Jack White Jack White

Jack is an accomplished trial lawyer and legal strategist who guides clients through complex challenges, including high-profile and sensitive litigation and government investigations. He focuses his practice on civil litigation, regulatory enforcement, and congressional investigations for clients in the defense, technology, federal contracting…

Jack is an accomplished trial lawyer and legal strategist who guides clients through complex challenges, including high-profile and sensitive litigation and government investigations. He focuses his practice on civil litigation, regulatory enforcement, and congressional investigations for clients in the defense, technology, federal contracting, higher and K-12 education, and other business sectors.

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Photo of Jason M. Vespoli Jason M. Vespoli

Jason focuses his practice on federal and state procurement, government technology, bid protests and government contract disputes, and regulatory compliance. He utilizes experience in state government, government technology, and complex procurement to solve problems in innovative and efficient ways.

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Photo of John Sullivan John Sullivan

John is an associate within the Government Investigations and White Collar Litigation group.

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Photo of Sophie Marsh Sophie Marsh

Sophie focuses her practice on government contracts and government investigations matters.

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  • Posted in:
    Administrative and Regulatory, Government and Public Policy
  • Blog:
    The FCA Insider
  • Organization:
    McGuireWoods LLP
  • Article: View Original Source

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