Tribal Leaders: Your Voice and Your Sovereignty Must Be Heard.

Today, the Office of Management and Budget (OMB) issued a Dear Tribal Leader Letter inviting Tribal Leaders to participate in consultation on proposed revisions to Title 2 of the Code of Federal Regulations (2 CFR), which governs administrative requirements, cost principles, and audit requirements for federal awards.

OMB has provided just five calendar days' notice of this consultation, an unacceptable and deeply inadequate timeframe for meaningful Tribal engagement.

The National Congress of American Indians (NCAI) does not consider this process to constitute meaningful Tribal consultation.

Nevertheless, it is imperative that Tribal Leaders participate and make their voices heard.

These proposed revisions will have significant implications for how Tribal Nations access, administer, manage, and account for federal funding. Changes to 2 CFR have the potential to directly affect Tribal governments' ability to implement programs, meet federal requirements, exercise self-governance, and deliver essential services to their citizens.

We must not allow an inadequate consultation process to result in the absence of Tribal Nations' perspectives from decisions that directly affect them.

TAKE ACTION: Participate in OMB's Tribal Consultation

OMB has announced two opportunities to provide input:

• IN-PERSON CONSULTATION

  • Monday, November 9, 2026

  • Washington, D.C.

• VIRTUAL CONSULTATION

  • Tuesday, November 10, 2026

  • Virtual participation

Tribal Leaders are strongly encouraged to attend one of these sessions, share their concerns, and clearly communicate the impacts these proposed revisions could have on Tribal Nations.

Participants will have up to three minutes to provide oral comments. Written comments will be accepted for up to five business days following the consultation sessions, which should be Wednesday, November 18, 2026.

To RSVP or ask questions: Contact the Office of Federal Financial Management at MBX.OMB.Grants@omb.eop.gov.

What Tribal Leaders Should Emphasize

NCAI encourages Tribal Leaders to make clear that:

• Five days' notice is not meaningful consultation. Tribal Nations need adequate time to review proposed changes, consult with their governing bodies, and prepare informed responses.

• Government-to-government consultation must be meaningful. Tribal Nations are sovereign governments, not stakeholders in a federal administrative process.

• Changes to 2 CFR have real consequences for Tribal Nations. Federal grant requirements directly affect Tribal program administration, staffing, compliance costs, access to resources, and the delivery of essential services.

• Tribal sovereignty and self-determination must be protected. Revisions should not create additional administrative burdens, undermine Tribal governance, or impose requirements that disregard the unique circumstances of Tribal governments.

• OMB must provide adequate opportunities for continued engagement. The agency must extend the consultation period and provide Tribal Nations sufficient time to review, analyze, and respond to the proposed rule.

NCAI's Position

NCAI strongly objects to the insufficient notice provided for this consultation and does not consider this process, as currently structured, to satisfy the standards of meaningful Tribal consultation. NCAI also strongly opposes this proposed rule.

Tribal Nations must have adequate time and opportunity to engage in matters that directly affect their governments, citizens, and sovereign authority. A five-day notice period for a government-wide regulatory proposal of this significance is wholly inadequate.

At the same time, NCAI urges every Tribal Leader who is able to participate to do so. Our collective presence and voices matter. We must ensure that federal decision-makers hear directly from Tribal Nations about the consequences of these proposed changes and the necessity of meaningful government-to-government engagement.

Do not let an inadequate process become an excuse for the absence of Tribal voices.

Please make every effort to attend, provide comments, and ensure your Nation's concerns are part of the record.

Our sovereignty demands meaningful consultation. Our participation ensures our voices are heard.

Resources:

Webinar: Overview of OMB Rule Proposing Significant Changes to Financial Assistance

Coalition for Tribal Sovereignty Comment Letter

MEM-26-049: Emergency Opposition to OMB Notice of Proposed Rulemaking FR-

2026-10817 and Demand for Government-to-Government Tribal

Consultation

SEA-25-009: Requiring Free Prior and Informed Consent by Corporations,

Companies, State and Federal Government Agencies Across the United States

and Globally

Contact Meghan Bishop, Director of Policy at policyinfo@ncai.org