Sneak Preview: USDA Implements New General Terms, Conditions

(The following was excerpted from a recent Thompson Grants Compliance Expert article.) All U.S. Department of Agriculture (USDA) financial assistance awards starting in 2026 now must follow the agency’s new general terms and conditions (GT&Cs), as directed under a recent memorandum from USDA Secretary Brooke Rollins. The new GT&Cs aim to “advance policies that put America First,” and require recipients “to adhere to standard practices consistent with sound stewardship of taxpayer dollars, transparency, accountability and alignment with the national security interests” of the U.S.

In federal fiscal year 2025, USDA’s 21 agencies and offices distributed more than $145 billion through 287 programs, and the agency currently oversees almost 51,000 active awards. The GT&Cs document “not only reduces government bureaucracy and makes it easier for USDA customers to access our programs, but it also strengthens our ability to take swift action when recipients — and even recipients of subawards and subcontracts — are not compliant with federal law and applicable executive orders,” Rollins added.

Agency officials noted that USDA recipients previously followed various terms and conditions depending on the program, “resulting in over 2,200 pages of terms and conditions across over 100 different documents.” Now all USDA grant and cooperative agreement programs will use the same 44-page terms and conditions.

According to Rollins’ Dec. 31, 2025, memorandum, the new GT&Cs implement several USDA policy priorities by:

• ensuring no recipients of USDA awards engage with or provide funding to entities or individuals on prohibited lists;
• enacting aggressive measures to prevent foreign adversaries from furthering their economic, strategic and military goals by exploiting American taxpayer funds administered by the department;
• standardizing termination language, which enables USDA to take decisive action for any awards that do not meet performance benchmarks or demonstrate substantial progress; and
• strengthening USDA control and oversight of obligated funds, and compliance with applicable laws, regulation and policy priorities, including standard requirements for advance payments, ensuring the prompt return of funds after termination, and requiring written prior approval of subawards and subcontracts under all awards.

(The full version of this story has now been made available to all for a limited time here.)

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