A 400-plus-page proposal to rewrite federal grant rules could reshape who can attend conferences, join associations and get reimbursed for event costs. OMB has proposed an October 1^st 2026 effective date — are you prepared?

A 400-plus-page proposal from the Office of Management and Budget wants to rewrite the rules governing how federal grant dollars can be spent on conferences, memberships and event services. If it takes effect as written on the scheduled October 1 date, planners who rely on federally funded attendees could be looking at a very different fall.

A comment period that broke records

On May 29, OMB — joined by roughly 40 other federal grantmaking agencies — published a proposed rule that would overhaul 2 CFR Part 200, the “Uniform Guidance” that has governed federal grants, cooperative agreements and other financial assistance since 2013. The rule would rename that guidance the “Uniform Grants Regulation” and, for the first time, give it binding regulatory force rather than the advisory status it has carried for more than a decade.

The public comment period closed July 13 with 341,699 comments filed — an extraordinary volume for a grants-management rulemaking. OMB has said it wants a final rule in place by October 1, 2026, the start of the federal fiscal year, though the agency has not yet indicated when it will act or how many of the proposed provisions will survive in their current form.

OMB frames the overhaul as a transparency and accountability measure aimed at rooting out what the agency’s Federal Register notice calls “wasteful spending” and “unlawful DEI mandates” in the grantmaking process, and at giving agencies more discretion to align awards with administration priorities. Buried inside that broader package, though, are four cost-principle sections that go directly to how associations, corporations and government contractors send people to conferences — and how meeting professionals get paid to help them do it.

The four sections planners need to know

Conferences (§200.432). Today, conference costs are allowable if they’re necessary, reasonable and allocable to the award — a standard that’s been in place for years. Under the proposal, attending a conference would only be an allowable cost if it is “expressly approved by the federal agency and included in the terms and conditions of the federal award.” In practice, that swaps a general standard for a specific, written pre-authorization requirement tied to each individual grant.

Advertising and public relations (§200.421). Advertising and PR costs — the kind of spending that gets the word out about an event — would become presumptively unallowable, with only narrow statutory or procurement-related exceptions.

Memberships and subscriptions (§200.454). Membership costs in professional, civic, business and technical organizations would require prior written agency approval and documented necessity to fulfill the specific award. Subscriptions to business, professional and academic periodicals would become categorically unallowable — a change several research and library groups have flagged because association membership and journal access are often bundled with conference registration.

Event services (§200.219), a new section. This provision would bar public entities that receive federal funds — public universities and convention facilities among them — from viewpoint-, content- or subject-matter-based discrimination in how they provide event services such as venue access, security and insurance. Several law firm analyses tracking the rule note that it would apply to events held on publicly controlled property regardless of whether the specific event is federally funded, which could complicate how public venues negotiate security and risk terms for controversial or high-profile bookings.

Two more provisions compound the effect: OMB proposes eliminating fixed-amount awards and subawards in favor of stricter cost-by-cost monitoring, and a separate pre-issuance review process (tied to Executive Order 14332) would insert senior political-appointee sign-off into discretionary award decisions — adding a layer of approval and delay upstream of the conference-cost question entirely.

Why Uncertainty May be as Consequential as Prohibition

For a perspective from an association whose members and event attendees often work within federally funded workforce programs, MeetingMentor spoke with Melissa Robbins, CEO of the National Association of Workforce Development Professionals.

Robbins said the shift matters less because of any outright ban on attendance and more because of what it does to certainty. Conference costs today have to be necessary, reasonable and allocable — established federal principles her association already builds its programming around. What the proposal does, she said, is require more explicit authorization from the funding agency and narrow the circumstances under which those costs are allowed at all.

That uncertainty, she argued, is the real threat. Federally funded attendees who aren’t sure whether their registration will be reimbursed tend not to take the risk. Robbins pointed to NAWDP’s annual conference, which typically attracts approximately 2,000 attendees. Based on the organization’s membership and attendee demographics, she estimates that more than 70% of attendees work in programs supported wholly or partly by federal funding. While the final rule and agency implementation remain uncertain, that means well over 1,400 professionals could potentially be affected by new approval requirements for conference attendance. Even if many ultimately receive approval, uncertainty about reimbursement and additional administrative hurdles could delay registrations or discourage participation altogether. “It’s that uncertainty often causes organizations and individuals to delay decisions or decide the risk isn’t worth taking.” Robbins said.

The effect wouldn’t stop at the registration line. Even for those who are eventually cleared to attend, Robbins expects the approval process itself to introduce delays that ripple into room-block commitments, reservation cutoff dates and food-and-beverage forecasting — the numbers hotel partners depend on to plan a group’s meeting space and staffing. “Even if the people are still able to come,” she said, “I think we’re still going to see impacts in a negative way to the way we do business.”

Membership carries its own exposure. Because attendance and membership are closely correlated for many associations, a narrower allowability standard for dues could suppress both revenue streams simultaneously — a “double whammy,” in Robbins’s words, that’s harder to offset than a hit to either one alone. During the pandemic, associations facing an attendance collapse could lean into membership and other revenue lines to stay afloat; this proposal would pressure both at once.

Force majeure, again

Robbins said her organization, like many others, strengthened its force majeure provisions after the pandemic to address certain governmental actions and regulatory changes. Whether any provision would apply here would depend on the final rule, its practical effect, the specific contract language and applicable law.

NAWDP is reviewing future event timelines and maintaining early communication with venue partners so it can respond appropriately once the final rule and implementation guidance are known. She’s already started conversations about the possibility of extended reservation cutoffs and delayed F&B guarantees, and said she’d rather have that groundwork in place and not need it than scramble in October.

Some organizations may respond by shifting programming toward hybrid or virtual formats, where a reduced registration fee is easier to justify than the full cost of travel, lodging and time away. Robbins was candid that this kind of pivot has its own ripple effects on the industry: Fewer in-person events means less demand for on-site AV, exhibit services, decor and off-site programming — the vendor ecosystem that depends on in-person attendance in the first place.

The industry’s response in Washington

The Exhibitions and Conferences Alliance (ECA), a coalition of trade and professional associations, formally opposed the proposal in comments to OMB Director Russell Vought. ECA President and CEO Tommy Goodwin told an industry publication the rule would undermine the federal government’s own return on the roughly $1 trillion it spends annually on grants, and that its language is broad enough to produce what he called “staggering” unintended consequences well beyond its stated DEI-related targets. ECA’s comment letter argues that an industry responsible for 2.6 million U.S. jobs and more than $400 billion in annual domestic spending deserves to have the rule withdrawn.

Trevor Mitchell, president and CEO of the International Association of Venue Managers and an ECA member, pushed back specifically on the event-services provision, arguing that public venues already operate in a nonpartisan manner and that the rule’s added bureaucratic steps around security funding could compromise, rather than improve, safety planning. “Venues should not be required to host events when they reasonably determine that adequate safety and security measures cannot be implemented,” he said in the article, “nor should they be required to absorb significant additional costs associated with mitigating event-specific risks.”

What to Watch — and Do — Next

Legal challenges are considered likely once (and if) a final rule is issued, though several law firms tracking the rulemaking note that OMB’s general authority to set government-wide financial management policy makes this a harder rule to enjoin than an executive order alone. Robbins said NAWDP is not taking a position on the viability of potential legal challenges. Its immediate focus is on administrative and legislative advocacy because those channels provide an opportunity to address the proposal before or during implementation.

In the meantime, her advice to planners tracks closely with what several law firms are telling their clients: Inventory which awards and events run past the proposed October 1 effective date and assume the new standard applies to them absent a transition provision; start documenting, event by event, why attendance is necessary, reasonable, allocable to the grant, how participation advances program outcomes and fulfills the award’s requirements; and identify now who would need to sign off on attendance if the rule takes effect, so that approval requests aren’t starting from zero in the fall. She also recommends looping in hotel and venue partners early — not to trigger force majeure discussions prematurely, but to flag that reservation cutoffs and attendee counts may need more flexibility than usual heading into Q4.

Whether OMB narrows any of these provisions in response to the comment record won’t be clear until a final rule is published. For an industry where a large and largely invisible share of attendees touch federal money in some way — not just government employees, but researchers, nonprofit staff and grant-funded professionals across health care, education and workforce development — the safest assumption for the next several months is that this rule matters to more of their audience than they think.