UC Comment Letters

This comment letter responds to the Office of Management and Budget (OMB)'s Proposed Rule to revise sections of 2 CFR, Subtitle A, Chapters I and II (the Uniform Guidance). UC expresses support for OMB’s burden-reducing changes but said the rule still leaves uncertainty and unrecovered costs around indirect-cost rates, agency IDC limits, outdated caps, DS-2 reporting, COI scope, and subaward rules. UC recommends clearer language, stronger enforcement of negotiated IDC rates, eliminating or updating outdated requirements, clarifying procurement COI, and preserving administrative flexibility.