Emily Chi Fogler and Marylana Saadeh Helou, Members of the Firm, and Laura DePonio, Associate, co-present "OMB Proposed Rule on Uniform Guidance: Legal Considerations," a webinar hosted by the Council on Governmental Relations (COGR).
The Office of Management and Budget's (OMB's) proposed rule, Regulation for Federal Financial Assistance, is set to permanently and significantly alter the federal research grants framework. In addition to preparing comments on specific OMB proposals, institutions may be thinking about the following broader legal questions, which this session addresses: (i) OMB's authority to issue the full scope of proposed changes as binding regulation in a compressed timeline; (ii) the legal implications of certain key proposals (e.g., DEI and gender ideology terms, termination authority, and foreign collaborations); and (iii) what to do in preparation for a final rule that may be effective October 1, 2026.
Emily, Marylana, and Laura lead a discussion on the proposed rule's legal vulnerabilities and the practical steps institutions should be taking now.
Topics include:
- OMB's authority to issue the proposed rule as binding regulation, and select legal vulnerabilities and potential challenges to that authority.
- Legal implications of the DEI, disparate-impact, and gender provisions, the foreign awards and collaborations restrictions, and the discretionary termination provisions.
- The comment period, which closes July 13, 2026, OMB's review obligations under Section 553 of the Administrative Procedure Act, and action items for institutions preparing for a final rule.
For more information, visit the event web page.
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