HHS has updated its standard Grant Policy Statement (GPS). As with the last two updates, this latest version of the GPS, contains significant changes but was released without any fanfare. The changes apply to all “awards and award modifications that add funding made on or after Oct. 1, 2025. This includes supplements to awards, competing and non-competing continuations.” They also “flow down to subrecipients.”
Key policy changes in the new GPS include:
- Completing the Uniform Guidance transition: These updates complete the transition of HHS grants from the HHS-specific Uniform Guidance (located at the old 45 CFR Part 75) to the Uniform Guidance used by most other Federal agencies, at 2 CFR 200. (There are now also HHS-specific rules at 2 CFR 300.)
- Termination for convenience: The GPS now states that a grant can be terminated if it “no longer effectuates the program goals or agency priorities” and that such decisions cannot be appealed.
- Tighter rules around:
- Budget revisions: Grantees must now get prior approval if they want to submit for cumulative budget revisions “expected to be more than 10% of the total budget amount approved by the agency, including cost share.” This replaces the prior 25% threshold of total approved direct costs.
- No-cost extensions must be requested at least 10 days “prior to the end of the budget period in the last year of the period of performance.”
- Title IX programs and “gender ideology”: Grantees that administer educational programs that are subject to Title IX (e.g., THCGME programs) must comply with the Executive Order on Defending Women from Gender Ideology Extremism, which implies that discrimination based on gender identity is not illegal. PCAs and CHCs have been seeing this language appear in Terms on the NOAs starting early this summer.
For more information on these GPS changes, see this blog post from Feldesman LLP.