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Topline Turmoil and Big Changes to OMB’s Uniform Guidance

Reported by Akingump
Jun 15, 2026· 3 min read
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Key Takeaways
  • • The House has advanced 11 of 12 appropriations bills through full committee markup as of mid-June 2026, with the Defense bill remaining; the Senate, meanwhile, remains gridlocked over fundamental disagreement on topline spending levels between Chair Susan Collins and Vice Chair Patty Murray.
  • • An OMB Proposed Rule set to take effect October 1, 2026, would substantially revise the Uniform Guidance (2 C.F.R. Part 200) governing federal financial assistance, introducing new fund prohibitions, pre-issuance political review processes, and expanded compliance obligations for grant recipients—a provision Democrats will likely contest in final FY 2027 negotiations.
  • • Reconciliation 3.0 appears effectively dead: Sens. Mitch McConnell and Susan Collins both stated last week that another reconciliation bill is unlikely, undermining President Trump's push for $350 billion in additional defense spending and his SAVE America Act, which faces Byrd Rule constraints.
  • • Senate appropriators face a structural funding crisis: with historical funding sources like IRS funds from the Inflation Reduction Act depleted or nearly exhausted, maintaining flat non-defense spending relative to FY 2026 requires billions in offsets, while Vice Chair Murray is unlikely to accept large defense increases without corresponding non-defense priority funding.
  • • The path to final FY 2027 appropriations legislation remains uncertain; while Chair Collins and Vice Chair Murray have historically returned to bipartisanship in difficult environments, fundamental mathematical gaps in funding availability and ideological divisions over policy riders present substantial obstacles through the August recess.
Summary
The fiscal year 2027 appropriations process faces a critical impasse as of mid-June 2026, with the House and Senate operating under starkly different political and procedural conditions. The House has moved aggressively through committee markups, advancing 11 of 12 appropriations bills through full committee on a largely partisan basis, with the Defense bill expected to complete markup on June 24 following the House recess. However, the Senate Appropriations Committee remains paralyzed by a fundamental disagreement over topline spending levels that boiled into public view during the week of June 11.

The deadlock centers on whether Chair Collins and Vice Chair Murray must reach a formal bipartisan understanding on total spending across all 12 bills before commencing markups. Murray has insisted on this traditional prerequisite; Collins initially resisted, citing concerns about poison pill amendments. Both leaders cite historical precedent for their positions, suggesting a breakdown in the customary bipartisan framework that has historically governed appropriations negotiations, even in contentious congressional environments.

A critical substantive issue emerging from House committee work involves an OMB Proposed Rule that would fundamentally reshape the Uniform Guidance for federal financial assistance. During markup of the Labor, Health and Human Services, Education and Related Agencies bill, Ranking Member Rosa DeLauro offered an amendment to block the rule, which is scheduled for implementation on October 1, 2026. The rule introduces new prohibitions on federal fund use, establishes a pre-issuance review process involving senior political appointees, and imposes expanded compliance obligations on grant recipients. The amendment failed 29-32, with one Republican voting in favor, signaling that this regulatory change will likely become a focal point in final conference negotiations between the chambers.

The underlying structural challenge confronting appropriators reflects years of reliance on rescissions and funding offsets from sources now depleted or nearly exhausted, including IRS funds from the Inflation Reduction Act. To maintain flat non-defense funding levels relative to FY 2026, Appropriators must identify billions in offsets, making significant new investments in priorities such as the Supplemental Nutrition Assistance Program or National Institutes of Health cancer research mathematically difficult without corresponding defense spending reductions—a dynamic Vice Chair Murray is unlikely to accept.

Separately, Reconciliation 3.0 appears effectively foreclosed. Both Sens. McConnell and Collins stated last week that another reconciliation bill is unlikely, directly contradicting President Trump's push for $350 billion in additional defense spending channeled through reconciliation alongside his SAVE America Act. The SAVE America Act would likely violate the Senate's Byrd Rule, which prohibits provisions lacking direct budgetary consequences, further complicating any potential pathway. With authorization levels in the National Defense Authorization Act excluding these funds, the mechanism for advancing the administration's defense spending request remains unclear. Senate leadership has signaled that substantive progress may not materialize until closer to the August recess, though traditional bipartisan instincts among appropriators offer some possibility of eventual negotiated resolution.

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Akingump Topline Turmoil and Big Changes to OMB’s Uniform Guidance