NCSHA Letter on Proposed Changes to the Federal Uniform Guidance

NCSHA submitted comments to the Office of Management and Budget (OMB) expressing concerns with proposed revisions to the Uniform Guidance, which governs the administration of federal financial assistance. While supporting OMB’s goals of improving transparency and accountability, NCSHA cautioned that several proposed changes would create significant uncertainty and administrative burdens for state HFAs and other federal grantees.
NCSHA urged OMB to preserve the stability and predictability that are essential for administering long-term affordable housing programs. Specifically, NCSHA recommended limiting expanded federal authority to suspend or terminate awards, establishing objective and transparent pre-award review standards, explicitly exempting formula grant programs such as HOME and CDBG from the new requirements, clarifying the responsibilities of pass-through entities, and maintaining notice-and-comment rulemaking for future substantive changes to the Uniform Guidance. NCSHA emphasized that these revisions should strengthen accountability without disrupting housing programs or increasing unnecessary compliance burdens.