The Trump administration is advancing a sweeping set of regulatory changes that, if implemented, could permanently destabilize how schools and educators receive and spend federal dollars.
New rules currently under review would add new restrictions on grant-funded efforts that clash with the current and future presidents’ policy positions, empower political appointees to intervene in ongoing awards and even terminate them early, and create new paperwork burdens for recipients of federal money.
The proposed revisions to what’s known as the federal government’s “uniform grants guidance,” managed by the White House Office of Management and Budget, have garnered widespread blowback, including from lawmakers, researchers, and education advocates.
So far, the Trump administration hasn’t changed course—but it remains to be seen how quickly these rules can take effect and whether political pressure to mollify widespread outrage will continue to mount.
“The bottom line here is that this process has made dealing with regs, working with grants today, much more unpredictable than we’ve ever seen before,” said Michael Brustein, an education lawyer who founded the Bruman Group firm that represents state education departments and school districts, during a recent webinar on the OMB proposals.
Here’s a look at the policies that could change and the implications for K-12 schools. Use the links below to jump to a specific question.
- What is OMB?
- What is the “uniform grants guidance,” or UGG?
- Which programs will be affected by the proposed changes?
- How does the current proposal to update the UGG differ from past changes?
- What are the specific changes OMB wants to make to the UGG?
- What are White House officials saying about the proposals?
- How is the Trump administration proposing to implement these changes?
- Who’s objecting to the proposed changes?
- How will schools be affected?
What is OMB?
The White House Office of Management and Budget coordinates presidential administration policy across federal agencies and supplies congressionally appropriated funds to agencies for spending.
Congress established OMB in 1921 to help the president draft his annual budget proposal. During the 1970s, the Nixon administration led a reorganization that brought OMB more directly under the president’s authority.
The current OMB director is Russell Vought, who also served in the role during the first Trump administration. Vought co-wrote large sections of Project 2025, the conservative policy document the administration has been closely following.
OMB during Trump’s second presidency has asserted much stronger and publicly visible involvement in federal policy actions and money management than during previous administrations, including Trump’s first. Vought has repeatedly claimed the executive branch has the constitutional authority to withhold or delay congressional spending that doesn’t align with the president’s priorities.
Currently, OMB has failed to dispense to the Education Department more than $2 billion Congress appropriated in February for competitive grants, including more than $1 billion set to expire on Sept. 30 if it goes unspent. Last July, OMB withheld for nearly a month close to $7 billion in formula funding that was due to flow to states for distribution to school districts, reversing course only after bipartisan backlash swelled.
What is the “uniform grants guidance,” or UGG?
OMB maintains and periodically updates a set of rules called the “uniform grants guidance,” which establishes procedures for federal grantmaking. The guidance is nonbinding—agencies can choose to adopt it or not. Most do.
The most recent update to the uniform grants guidance came in 2024, during President Joe Biden’s administration.
Which programs will be affected by the proposed changes?
The uniform grants guidance covers all federal discretionary grant awards—more than $2 trillion a year in total. That includes billions of dollars for dozens of competitive education programs that support literacy initiatives, charter school development, teacher-training programs, education research, and a wide variety of other priorities.
Portions of the proposed changes also apply to formula grants, including education programs like Title I—aimed at disadvantaged students—and the Individuals with Disabilities Education Act.
Some funds within certain programs—including Impact Aid for districts with large amounts of nontaxable federal property and the National School Lunch Program—are specifically exempt from portions of the guidance.
How does the current proposal to update the UGG differ from past changes?
OMB under Trump and Vought is proposing a slew of changes to the substance of the guidance—we’ll dig into those more below.
But first, it’s important to understand the fundamental change that could be on the horizon. OMB is proposing to make the Uniform Grants Guidance binding, which would mean the terms of the document—and future updates—automatically apply across the federal government.
What are the specific changes OMB wants to make to the UGG?
The guidance would give politically appointed agency officials the power to review and approve—or reject—all discretionary, or nonformula, grants before they’re awarded to the intended recipient. The rules don’t specify the appointee’s qualifications, or their specific positions within the agencies. Currently, independent peer reviewers provide the final word on which grants are and aren’t awarded.
Those political appointees would also be empowered with much more leeway than ever before to cancel grants midway through their award period. They would be the “ultimate deciders,” said Hal Duncan, OMB’s associate director of legislative affairs, during a Senate confirmation hearing last month for his nomination to serve as Vought’s second-in-command.
Meanwhile, the Department of Justice would be empowered to back private individuals who file lawsuits alleging harm from federally funded work.
If the new guidance goes into effect, federal grant recipients would also face a slew of new restrictions. They’d no longer be able to spend federal dollars on anything associated with discriminatory “diversity, equity, and inclusion;” allowing minors to pursue gender-affirming care; facilitating “illegal immigration;” and promoting “anti-American values.” The proposed rules generally don’t define those terms or provide specific examples.
Grants would also be prohibited from promoting or supporting “disparate impact liability”—the concept, enshrined in federal civil rights law, that seemingly neutral policies can create disproportionately negative impacts on certain marginalized groups.
Recipients of federal funding would also have new obligations to justify individual expenses in writing. Spending federal grant funds on conference travel for professional development and advertising (including, potentially, for job fairs and other recruitment efforts) would no longer be allowed. And states would be required to conduct additional layers of verification before disbursing federal grant funds intended for school districts.
What are White House officials saying about the proposals?
During a U.S. House of Representatives hearing on June 30, Vought framed the changes as an effort to implement an executive order Trump signed last August, which called for each agency to designate a political appointee to oversee grants.
“This regulation is catching up with that executive order to make sure it’s actually reflected in the actual mechanics of grantmaking,” Vought said.
Vought said the changes aren’t “anti-science” and disputed the suggestion that the new rules would lead to the federal government canceling grants en masse.
Rather, he said, OMB would empower federal agencies to halt objectionable projects before they become even more damaging.
“When we find something that is problematic that our policy officials would not have caught, we need to turn it off,” Vought said.
How is the Trump administration proposing to implement these changes?
OMB published these proposed changes on May 29 with little fanfare, kicking off a mandatory public comment period that’s set to close on July 13.
The proposal identifies Oct. 1—the start of the federal 2027 fiscal year—as the implementation date for the final version of the rule changes.
Members of the public can continue commenting on the rule until July 13. As of July 7, more than 93,000 comments have flooded in—compared with 2,200 last time the federal government proposed changing the UGG. The Trump administration is required by law to respond to all comments, no matter how many there are.
Some of the proposed changes codify practices the Trump administration has already used over the last year and a half, including citing DEI-related initiatives to justify revoking hundreds of ongoing grants.
Some agencies, including the Education Department and the National Science Foundation, have already begun advancing adoption of the UGG changes in their own regulations.
Who’s objecting to the proposed changes?
A wide variety of affected groups across the political spectrum have weighed in opposing OMB’s proposed changes.
Advocates for health and science research have been particularly vocal. The president of the American Association of Medical Colleges described the rules as an unprecedented threat. Stand Up for Science, an advocacy organization, estimated that roughly half of ongoing federally funded health research efforts could run afoul of the new rules if they’re implemented as drafted.
All 47 members of the Democratic Senate caucus blasted the proposed changes in a July 1 letter to Vought urging the Trump administration to reverse course entirely.
“Your proposal exceeds OMB’s authority, will make it impossible for grant recipients to faithfully carry out the funding priorities that Congress establishes in statute, and would turn federal grants into a new cudgel for the President to unilaterally advance his partisan agenda and punish political rivals,” the senators wrote.
The prospect of grants getting canceled for any reason has been particularly alarming to some—particularly given that numerous courts have reprimanded the Trump administration for illegally doing just that in the last year and a half.
“They’re basically taking that disregard for precedent and what the procedures say, taking that and making it part of the law,” said Josie Skinner, an education lawyer for the Sligo Law Group who previously worked as an attorney for the U.S. Department of Education. “Now instead of ignoring the law, they have introduced this arbitrariness into the law itself.”
Some critiques of the proposals have also emerged from Republicans and right-leaning observers.
Sen. Susan Collins, R-Maine, on July 7 called for the Trump administration to add 90 days to the public comment period for the rule changes and withdraw portions of the proposed changes.
In particular, she said, she opposes the involvement of political appointees in grantmaking, the option for agencies to terminate grants without warning, and the requirement that federally funded projects align with the president’s priorities.
“The rule would impose new, burdensome requirements on award recipients that would harm small and rural communities, undermine scientific and biomedical research, and conflict with Congress’ control over the federal funding process,” wrote Collins, who chairs her chamber’s appropriations committee.
Some conservative economists have also argued that the rules would give the current president and his successors too much unchecked power—while adding layers of paperwork and bureaucracy in the process.
How will schools be affected?
Federal funding makes up roughly 10% of annual K-12 spending nationwide. A sampling of the public comments on the OMB proposal suggest a slew of ways in which the changes could have tangible effects on school districts.
Immediate grant terminations without warning “could disrupt student services and reduce the effectiveness of federally funded initiatives,” wrote a federal programs director from a Michigan school district.
A federal programs director from a public school district in Texas said the restrictions on conference attendance will “deny key training and assistance” for professionals with few colleagues in their districts who have similar roles.
A school finance official in Pennsylvania called on OMB to separate formula funding from the discretionary grants that would be subject to immediate termination at any time.
A district administrator in Massachusetts wrote that the adoption of the restrictions on acknowledging the existence of transgender people “would require my district’s counselors and school psychologists to deny the mental health needs of our students, according to the guidance of their own professional bodies, or lose funding for those same students’ education.” Staff would be affected, too: “Some of my strongest educators are trans adults,” the administrator wrote.
Several commenters from schools—as well as a separate statement from the National Education Association—highlighted the chilling effect that broad discussion of a grants crackdown could have on efforts to secure federal funds for crucial programs, especially in districts that already struggle financially.
As one Washington state administrator put it, “Limiting access to opportunities with experts in critical areas school districts now face may disproportionately affect districts with fewer local resources and professional learning options and would therefore negatively impact students and their access to a high quality, safe instructional environment.”
