As federal grant recipients navigate evolving priorities and enforcement trends, the core requirements for subrecipient oversight—outlined in 2 CFR §§ 200.331–.333—remain unchanged. While no immediate regulatory modifications have occurred, pass-through entities should anticipate potential shifts in risk assessments, reporting expectations, and enforcement actions.

To stay ahead, organizations should reassess subrecipient risk management, strengthen documentation and internal controls, enhance communication, and monitor regulatory updates. By reinforcing compliance practices now, grant recipients can position themselves for regulatory alignment and operational efficiency in an evolving grants environment.

Recent executive orders have raised questions about their impact on federal funding, leaving many grant recipients uncertain about what, if anything, needs to change in their grant management practices. While political debates continue, organizations must focus on compliance with regulations as they stand today.

This article breaks down key considerations for grant recipients, including:
✅ How the Code of Federal Regulations (CFR) is updated and the timeline for changes.
✅ How Diversity, Equity, and Inclusion (DEI) policies are embedded in multiple regulations, policies, and acts.
✅ Proactive steps to ensure compliance with executive orders while managing grants, particularly under 2 CFR 200.

Understanding the CFR update process, recognizing DEI’s regulatory impact, and implementing strong compliance strategies will help organizations navigate evolving policies with clarity and confidence. Compliance should always be rooted in current law.