Sneak Preview: State Dept. Adds Award Terms to 2 C.F.R. Part 600
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) The Department of State, to address specific priorities under the Trump administration, recently issued three final rules that add new terms and conditions for recipients of foreign financial assistance from the agency. These rules become effective on Feb. 26.
The Office of Management and Budget uniform guidance is located at 2 C.F.R. Part 200 in subtitle A of Title 2, while agency-specific guidance and exceptions related to federal financial assistance are found at subtitle B of Title 2. These three rules, provided in the Jan. 27 Federal Register, are being added to the State Department’s agency-specific regulations and exceptions at 2 C.F.R. Part 600. These terms and conditions will be incorporated as applicable for amendments to the agency’s grants and cooperative agreements when new funds are added, as well as into new awards.
The agency is calling these rules the “Promoting Human Flourishing in Foreign Assistance (PHFFA) Policy,” adding that they are consistent with provisions in 11 of Trump’s executive orders and memoranda issued since January 2025. Of note, the agency explains that these regulations implement Trump’s memorandum expanding on the 1984 Mexico City Policy, which prohibits foreign nongovernmental organizations (NGOs) from performing, promoting or funding abortions as a method of family planning, to also include the administration’s priorities relating to prohibitions on diversity, equity and inclusion (DEI) initiatives and gender-affirming care. “To ensure that foreign aid is aligned with administration policy and promotes human flourishing, the Secretary of State has directed that foreign assistance align with State Department policies opposing gender ideology, discriminatory equity ideology, unlawful DEI programs and abortion as a method of family planning overseas,” according to the department.
The first rule includes a new regulation at 2 C.F.R. Part 604 entitled “Combating Discriminatory Equity Ideology in Foreign Assistance,” which imposes certain requirements relating to discriminatory equity ideology on foreign NGOs, U.S. NGOs, international organizations (IOs), foreign governments and parastatals.
(The full version of this story has now been made available to all for a limited time here.)
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