GSA Grant Certification Proposal

What happened:
On January 28, 2026, the General Services Administration (GSA) proposed new certification requirements for every organization that receives federal funding, grants, cooperative agreements, loans, and more. To receive any federal financial assistance, nonprofits must register through SAM.gov, the System for Award Management. The proposal would add new pledges to that registration process, requiring organizational leaders to certify that:

• Your organization doesn’t run DEI programs the current Administration considers discriminatory, including cultural competence training and diversity statements.
• You comply with executive orders that legally apply only to federal agencies, not nonprofits.
• Your organization doesn’t harbor, transport, or shield undocumented individuals – potentially including organizations providing legal services, shelter, or health care to immigrant communities.

The core problem? None of the key terms are defined. There’s no clear explanation of what counts as a violation, which executive orders apply, or how compliance works across partner organizations and subrecipients. False certifications carry False Claims Act liability and potential criminal penalties. This means nonprofit leaders are being asked to sign a legal certification they can’t fully evaluate – with criminal liability attached if the Administration later decides you got it wrong. The public comment period closed March 30, with over 1,300 nonprofits signing a National Council of Nonprofits-led opposition letter.

What it means for Pennsylvania nonprofits:
Any organization receiving federal funding would face this, but those running equity-focused programs and/or serving immigrant communities will be the most directly impacted.

Where things stand (as of April 6, 2026):
The GSA must review public comments before issuing a final rule. The volume of opposition creates real pressure for revision, but litigation is expected regardless. PANO will share updates as the rule develops.