Now Is the Time to Speak Up
A proposed federal rule could make it harder for grant-funded professionals to participate in associations, attend association conferences, and access professional publications. Association leaders should not wait to feel the impact—or to make their voices heard.
Proposed Rule Impacts Membership, Subscriptions & Conference Attendance
On May 29, the White House Office of Management and Budget published a proposed rule, Regulation for Federal Financial Assistance, that would revise the Uniform Guidance governing federal grants and cooperative agreements under 2 CFR Part 200.
Several proposed changes could directly affect associations and the members they serve.
Membership - Under the proposal, federal grant funds could be used for membership in professional, civic, business, and technical organizations only when the membership is necessary to fulfill the award requirements and approved in advance by the federal agency. Subscriptions to business, professional, academic, and technical periodicals would become unallowable. Membership in organizations whose primary purpose is lobbying or issue advocacy would also be unallowable.
Conferences - The proposed rule would also limit conference attendance. Costs for attending conferences would be allowable only when participation is expressly approved by the federal agency and included in the terms and conditions of the federal award.
Association Leaders Should Act Now
Organizations affected by this proposal should consider submitting comments to OMB explaining how association membership, conferences, professional publications, and peer learning support effective grant administration and public outcomes. The most persuasive comments will include specific examples: how members use association education to comply with federal requirements, how conferences improve implementation, and how professional resources help prevent errors, duplication, or misuse of funds.
Association comments may ask OMB to preserve reasonable allowability for professional memberships, conferences, and publications when they support grant performance, compliance, workforce development, technical assistance, or program outcomes. Comments may also urge OMB to clarify how “issue advocacy” will be defined so that organizations are not penalized for engaging in legitimate education, policy analysis, standards development, or member guidance.
MSAE has drafted possible talking points as a general resource to help association leaders evaluate the proposed OMB rule and organize their own comments.
How to Submit Comments
Comments are due to OMB by July 13, 2026.
To comment:
-
Go to Regulations.gov.
-
Search for docket OMB-2026-0034.
-
Look for the proposed rule titled “Regulation for Federal Financial Assistance.”
-
Submit comments electronically through the docket before the deadline.
-
At the beginning of each comment, identify the section being addressed in brackets. For example:
-
[200.432] for comments about conference attendance.
-
[200.454] for comments about memberships, subscriptions, and professional activity costs.
-
Do not include confidential business information, sensitive personal information, or anything you would not want posted publicly.
This is a moment for association leaders to explain the real-world value associations provide. Federal grant rules should promote accountability without cutting grant-funded professionals off from the education, expertise, and communities of practice that help them do the work well.
🚨Call to Action: Comment on Federal Grant Rules
A proposed federal rule could make it harder for grant-funded professionals to participate in associations, attend association conferences, and access professional publications. Association leaders should not wait to feel the impact—or to make their voices heard.
Proposed Rule Impacts Membership, Subscriptions & Conference Attendance
On May 29, the White House Office of Management and Budget published a proposed rule, Regulation for Federal Financial Assistance, that would revise the Uniform Guidance governing federal grants and cooperative agreements under 2 CFR Part 200.
Several proposed changes could directly affect associations and the members they serve.
Membership - Under the proposal, federal grant funds could be used for membership in professional, civic, business, and technical organizations only when the membership is necessary to fulfill the award requirements and approved in advance by the federal agency. Subscriptions to business, professional, academic, and technical periodicals would become unallowable. Membership in organizations whose primary purpose is lobbying or issue advocacy would also be unallowable.
Conferences - The proposed rule would also limit conference attendance. Costs for attending conferences would be allowable only when participation is expressly approved by the federal agency and included in the terms and conditions of the federal award.
Association Leaders Should Act Now
Organizations affected by this proposal should consider submitting comments to OMB explaining how association membership, conferences, professional publications, and peer learning support effective grant administration and public outcomes. The most persuasive comments will include specific examples: how members use association education to comply with federal requirements, how conferences improve implementation, and how professional resources help prevent errors, duplication, or misuse of funds.
Association comments may ask OMB to preserve reasonable allowability for professional memberships, conferences, and publications when they support grant performance, compliance, workforce development, technical assistance, or program outcomes. Comments may also urge OMB to clarify how “issue advocacy” will be defined so that organizations are not penalized for engaging in legitimate education, policy analysis, standards development, or member guidance.
MSAE has drafted possible talking points as a general resource to help association leaders evaluate the proposed OMB rule and organize their own comments.
How to Submit Comments
Comments are due to OMB by July 13, 2026.
To comment:
Go to Regulations.gov.
Search for docket OMB-2026-0034.
Look for the proposed rule titled “Regulation for Federal Financial Assistance.”
Submit comments electronically through the docket before the deadline.
At the beginning of each comment, identify the section being addressed in brackets. For example:
[200.432] for comments about conference attendance.
[200.454] for comments about memberships, subscriptions, and professional activity costs.
Do not include confidential business information, sensitive personal information, or anything you would not want posted publicly.
This is a moment for association leaders to explain the real-world value associations provide. Federal grant rules should promote accountability without cutting grant-funded professionals off from the education, expertise, and communities of practice that help them do the work well.
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