Re: Docket No. OMB-2026-0034 — Proposed Rule, “Regulation for Federal Financial Assistance” (91 Fed. Reg. 32,198, May 29, 2026), Amending 2 C.F.R. Part 200 (Uniform Guidance)
First Focus on Children filed comments with the Office of Management and Budget to withdraw a proposed rule that would allow the federal government to cancel grants and defund children’s programs practically overnight.
In the comments, First Focus on Children urges OMB to withdraw this proposed rule in its entirety.
The rule exceeds OMB’s authority under the Chief Financial Officers Act and Congress’s power of the purse. It lets political appointees terminate or suspend federal awards without cause under an ill-defined “national interest” standard (§200.340), with no hearing and no binding appeal. Federal courts in Rhode Island and DC have already rejected OMB’s claim that the CFO Act authorizes this kind of unilateral action. This exposure falls disproportionately on children.
Children’s programs are concentrated in discretionary, competitively awarded grants — exactly what this rule places in the crosshairs — rather than in the mandatory entitlement funding that shields programs serving primarily adult populations. According to First Focus on Children’s Children’s Budget 2025 and Babies in the Budget 2025 analyses, children’s programs already receive only about 8.57% of federal spending, and infant/toddler programs just 1.59%, both declining sharply since 2021.
The rule’s political pre-issuance review provision (§200.205) would displace scientific peer review of pediatric and child health research, contradicting the Administration’s own “Gold Standard Science” guidance prioritizing unbiased peer review. Its prohibition on funding services connected to immigration status (§200.205(b)) threatens legal representation, shelter, and case management for unaccompanied children. Its disparate-impact prohibition (§200.218) would bar exactly the kind of analysis needed to close persistent, documented gaps, such as the more-than-two-to-one disparity between Black and white infant mortality rates.
If OMB proceeds despite these flaws, it should at minimum require a Child Impact Statement before any pre-issuance review, condition change, termination, or suspension affecting an award whose primary beneficiaries are children — describing the children served, the effect on continuity of services, and any risk to their health, safety, or development. Children have no vote and no lobbyist in this process; a Child Impact Statement would help ensure they are not simply invisible to it.
We also renew the request made by many other commenters that OMB extend the comment period and abandon the October 1, 2026 effective date.