Comment on OMB-2026-0034-0001

Pima County, Arizona respectfully submits the comments in the attached letter in response to the Office of Management and Budget's (OMB) proposed rule rewriting 2 CFR Part 200 – commonly known as the Uniform Guidance – published in the Federal Register on May 29, 2026 (Docket OMB-2026-0034). This rulemaking represents the most significant revision to federal grant administration since the creation of the Uniform Guidance in 2013, and its scope and complexity demand the most thorough stakeholder input possible. In FY26, Pima County administered a total grant portfolio of approximately $490 million in federal grant awards across approximately 250 distinct federal grants, supporting critical services including public safety, transportation, public health, housing, environmental programs, economic development, and community services. These funds are delivered directly to residents and, in many cases, passed through to local subrecipients and community organizations. The proposed rule would affect every aspect of how we apply for, administer, and account for those funds. We appreciate OMB's stated objectives of improving transparency, accountability, and oversight of federal financial assistance – and we share those goals. Pima County maintains robust internal controls, documented policies and procedures, and a strong audit record. We submit these comments to ensure the final rule reflects the operational realities of our county and preserves our ability to effectively deliver federally funded services to our communities. Please see the attached letter, which addresses Pima County's concerns with specific sections of the proposed rule and how the changes could negatively impact Pima County, and posits alternative actions for your consideration.