The Office of Management and Budget has released a proposed rule ( https://www.federalregister.gov/documents/2026/05/29/2026-10817/regulation-for-federal-financial-assistancelargely) solidifying President Trump's August 2025 Executive Order 14332 "Improving Oversight of Federal Grantmaking" which overhauls how the federal government makes and eliminates federal grants given by most of the federal government, including block grants and individual grants.
AIA National is looking for information regarding the grants you use to do your work or otherwise benefit from:
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Details on the grants themselves, including whether they are block grants (funds to state or local governments for a broad function, often suballocated) or categorical/project/formula grants (often awarded directly to nonprofits, universities, or individual researchers).
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Looking at the key concerns, including that grants need to be pre-cleared by a political appointee and can be revoked at any time for no longer aligning with the president's policy priorities, do you anticipate problems getting grants for your work?
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What could be the impact of a reduction in federal grants on your work/state/city/project?
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Specific examples or policy documents you or your association has made are welcome. This rule impacts a huge swath of the country.
Please post your perspective here for Brittany Meyer, Director, Government Affairs & Public Policy may connect with you about your experience.
Key points of concern:
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Senior political appointees must pre-clear all awards and make sure they align with the president's policy priorities which includes: anti-"woke" and gender issues, immigration issues, "anti-American values", anything that's not in line with the administration.
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Agencies have explicit authority to terminate awards whenever they no longer advance program goals, agency priorities, or the "national interest," and all awards must include stop‑work suspension language.
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For terminations, agencies need only provide brief written notice; there is no longer any requirement to provide hearings or appeal rights.
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Recipients must mitigate obligations upon suspension/termination, with agencies having wide discretion whether to cover termination‑related costs.
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Fixed amount awards are eliminated and fixed amount subawards are prohibited; as they provide inadequate transparency and oversight.
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Pass through entities must classify payments to affiliates/subsidiaries as subawards or contracts (no "internal transfer" workaround), and must police subrecipient conduct that could harm the reputation of the entity, the agency, or the federal government.
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Bar on using grant funds for collaborations, agreements, programs, or activities with China or Chinese‑owned companies, and more broadly with any "foreign adversary," "country of particular concern," or sanctioned country, unless a specific statute authorizes it.
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Costs for conference attendance, memberships in professional/civic/technical organizations, subscriptions to professional/academic journals, and fundraising/investment activities become unallowable or allowed only with prior written approval.
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Advertising and public‑relations costs are broadly unallowable, and federal funds may not be used for voter registration, certain issue advocacy, lobbying of state executives, or elective abortions.
Thanks!
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Matthew Hutchins AIA
CAST architecture
Seattle WA
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