Proposed Federal Grant Changes
Affecting CoC Recipients
Dear CoC Providers and Stakeholders,
Two federal proposals could significantly affect Continuum of Care grant administration. Neither changes current requirements.
OMB’s proposed revisions to the Uniform Guidance (2 CFR Part 200) would expand federal oversight and federal agencies’ authority to suspend or terminate certain awards. They would also increase grant recipient responsibilities for subrecipient oversight and require recipients to confirm that required subaward information was reported through SAM.gov.
Separately, HUD is proposing enhanced financial reporting for grants subject to related special conditions. Affected recipients would submit supporting records through a new portal—generally quarterly—including invoices, proof of payment, and certain subaward agreements or contracts. The records would cover expenditures made by recipients, subrecipients, and contractors.
The HUD requirement would not automatically apply to every CoC grant; it would apply to awards carrying the special condition. However, HUD says it is currently adding such conditions to grant awards and estimates that up to 30,000 HUD grantees could be affected. The notice does not explain how HUD will determine which individual awards receive the condition. However, under the Uniform Guidance (2 CFR § 200.208), federal agencies may impose special conditions based on a risk assessment of a recipient. Factors HUD may consider include:
- A recipient’s history of compliance with federal awards;
- Whether the recipient has demonstrated the ability to meet performance expectations;
- Financial management capacity;
- Information from government-wide responsibility databases and other available risk information.
Public comments on this proposal are due September 8, 2026.
We will share updates if either proposal is finalized or HUD provides additional implementation guidance.
Sincerely,
CT BOS Team