ISACo thanks the National Association of Counties (NACo) for partnering with us to provide updates and information about federal issues of importance to counties.
OMB Uniform Guidance Changes Delayed Until December 11
Counties received additional time to prepare for potentially significant changes to the federal rules governing grants and cooperative agreements.
The Office of Management and Budget (OMB) has proposed a major rewrite of the Uniform Guidance contained in 2 CFR Part 200. These rules govern how counties and other recipients administer federal grants, including requirements involving costs, audits, pass-through awards and grant termination.
Implementation has been delayed until December 11, 2026, under the continuing resolution approved by Congress and signed into law by President Trump on September 2, 2026. NACo continues to seek additional congressional action to further delay implementation while concerns raised by counties and other stakeholders are considered.
The proposed changes could affect county budgeting, compliance, procurement and program administration. NACo is encouraging counties to communicate with members of Congress about potential local impacts and has developed resources and template letters to assist those advocacy efforts.
Why It Matters to Counties: Counties administer a wide range of federally funded programs. Changes to the Uniform Guidance can therefore affect not only federal compliance requirements but also the costs and administrative responsibilities associated with delivering services locally.
Federal Government Funding Extended Through December 11
The aforementioned continuing resolution signed into law on September 2, 2026, also funds the federal government through December 11, 2026, setting up another consequential appropriations deadline near the end of the year.
At the end of September, none of the 12 regular federal appropriations bills had completed the legislative process and been signed into law.
Congress will return following the November elections with a relatively short legislative window before the December 11 deadline and subsequent holiday recess. Lawmakers could attempt to complete individual appropriations measures, negotiate a larger year-end funding agreement or approve another continuing resolution.
Why It Matters to Counties: Federal appropriations support numerous programs administered by or benefiting counties. Uncertainty surrounding appropriations can complicate county budgeting and program planning, while a lapse in federal funding can disrupt grant administration and other federal-local partnerships.
ISACo will monitor negotiations as Congress approaches the December deadline.
Proposed 2030 Census Changes Could Affect Counties
The U.S. Census Bureau has proposed significant changes governing the 2030 Decennial Census.
On September 10, the Census Bureau published a proposed rule that would add two new parts to Title 15 of the Code of Federal Regulations. Among other changes, the proposal would establish new standards for determining an individual’s “usual residence,” restrict the apportionment count to U.S. citizens and lawful permanent residents, establish an enumeration period running from January 3 through April 1 and prohibit questions concerning race, ethnicity and sexual orientation from appearing on the questionnaire used to enumerate the population.
The proposal is significant for county governments because Census data are used extensively in the distribution of federal resources. NACo reports that Census data help determine the distribution of approximately $2.8 trillion annually across 353 federal programs.
Why It Matters to Counties: Changes affecting who is counted or where individuals are counted could alter official population totals. Those totals can affect federal funding formulas as well as county planning, infrastructure decisions, economic development and other governmental functions.
County Action Needed — Comments Due October 13
Illinois counties have an opportunity to formally comment on the proposed rule before the Census Bureau makes a final decision.
Public comments must be received by October 13, 2026. The Federal Register notice identifies the rulemaking as Docket No. USBC-2026-0628.
Counties can submit comments electronically through Regulations.gov. Search for USBC-2026-0628, select the “Comment” option and either enter comments directly or attach a prepared comment letter. Comments can also be mailed to:
U.S. Census Bureau
4600 Silver Hill Road
Designation: ADDEMO/FRN
Washington, DC 20746
NACo recommends that counties make their comments as specific as possible. Comments should identify the particular section of the proposed rule being addressed and, when applicable, quantify potential impacts on federal funding or county operations. NACo also recommends sharing submitted comments with the county’s U.S. House member and both U.S. Senators.
Submit comments through Regulations.gov
Review NACo's county guidance on the proposed Census rule
Permitting Reform Remains Unsettled
Congress continues to consider legislation intended to streamline federal permitting processes.
The House has advanced permitting reform legislation, while bipartisan Senate negotiations have encountered difficulties. Recent Senate discussions have included disagreements involving offshore wind projects that have complicated efforts to reach agreement on a broader permitting package.
The issue remains relevant to counties because federal permitting requirements can affect infrastructure, transportation, energy and economic development projects involving local governments.
Why It Matters to Counties: Changes to federal permitting requirements could influence project timelines, regulatory responsibilities and the ability of counties to advance infrastructure and economic development projects involving federal approvals or funding.
ISACo will continue monitoring congressional negotiations and keep counties informed about the status of the legislative permitting package.
What We're Watching
In summary, several federal issues could develop over the next several weeks:
- Congressional action ahead of the December 11 federal funding deadline;
- The future of OMB’s proposed Uniform Guidance changes;
- County participation in the Census Bureau rulemaking before the October 13 comment deadline;
- Developments involving conditions attached to federal grants; and
- Congressional negotiations over federal permitting reform.
ISACo will continue working with NACo and monitoring developments in Washington, D.C., to keep Illinois counties informed about federal actions affecting county finances, authority and operations.