The Cost Openness and Spending Transparency (COST) Act adds a new section (31 U.S.C. §1356) requiring Executive and independent regulatory agencies—and any individual or entity carrying out programs with federal funds—to state the federal percentage and dollar amount financing any program, project, or activity in specified public communications. It also requires recipients to certify compliance in performance progress reports, directs OMB to sample and publish compliance findings annually, and obliges OMB to create an anonymous public reporting mechanism within one year.
This matters because the bill moves cost-disclosure responsibilities beyond budget documents into everyday public-facing materials (press releases, RFPs, solicitations and similar documents). That widens what the public can use to determine how much of a program is federally funded, but it also creates new operational and verification obligations for agencies, grantees, contractors, and subrecipients—especially smaller recipients with limited compliance capacity.
At a Glance
What It Does
The bill adds 31 U.S.C. §1356, which requires covered entities to include the federal percentage and dollar amount of funding, and the nongovernmental share, in most public descriptions of federally funded programs. It exempts communications of 280 characters or fewer and requires recipients to certify compliance in progress reports.
Who It Affects
Executive and independent regulatory agencies, federal grant recipients (including states, local governments, universities, research institutions, nonprofits), contractors responding to solicitations, and communications teams that issue public materials about federally funded work.
Why It Matters
It extends transparency requirements into routine public communications and creates an OMB-driven compliance and reporting regime. For compliance officers and grant managers, the bill imposes new disclosure mechanics, verification steps, and potential operational costs tied to everyday outreach and solicitation documents.
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What This Bill Actually Does
The bill creates a statutory obligation for agencies and anyone carrying out federally funded programs to disclose the federal share and dollar amount of costs in public-facing materials that describe those programs. Covered communications explicitly include statements, press releases, requests for proposals, bid solicitations, and “other documents” that describe the program, project, or activity.
The only communications excluded are those that are 280 characters or fewer, which appears aimed at keeping very brief social posts out of the requirement.
Recipients must include, in their performance progress reporting, a certification about whether they complied with the disclosure rule. That moves some compliance responsibility onto grantees and contractors rather than leaving it solely with federal agencies.
The bill also requires the Director of OMB to perform an annual compliance check by reviewing a random sample of public communications and to publish the findings, creating a public record of how well agencies and recipients follow the rule.Finally, OMB must implement an anonymous, public-facing mechanism within one year for anyone to report communications that allegedly fail to meet the disclosure requirements. That reporting tool must accept the noncompliant communication or its location and identifying information about the federally funded program.
The combination of certification, OMB sampling, and public tip reporting is the bill’s enforcement architecture; the text does not prescribe civil penalties or specific corrective actions for noncompliance, leaving follow-up and remedies to OMB or other existing oversight channels.
The Five Things You Need to Know
The bill adds a new statutory section—31 U.S.C. §1356—creating a legal duty to disclose funding shares in public descriptions of federally funded programs.
Covered communications include press releases, statements, requests for proposals, bid solicitations, and other documents that describe a program, but exclude communications of 280 characters or fewer.
Recipients must certify in their performance progress reports whether they complied with the disclosure requirement, tying the duty to existing reporting processes.
OMB must annually review a random sample of public communications for compliance and publish the results of that review.
Within one year of enactment, OMB must provide an anonymous public mechanism to report communications that do not comply, including the noncompliant communication or its location and identifying program information.
Section-by-Section Breakdown
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Short title
Establishes the Act’s name as the 'Cost Openness and Spending Transparency Act of 2025' (COST Act). This is purely cosmetic but important for citation and cross-referencing in regulations and agency guidance that will follow if the law is enacted.
Who the law covers
Defines 'agency' to include Executive agencies (per 5 U.S.C. §105) and independent regulatory agencies (per 44 U.S.C. §3502). That definition makes the disclosure obligation applicable across the federal executive branch and independent bodies, ensuring a broad sweep that reaches most federally funded programs and activities.
Disclosure content and covered documents
Requires that any relevant public communication describing a program, project, or activity that is funded in whole or in part with federal funds must state: (1) the percentage of total costs financed with federal funds; (2) the dollar amount of federal funds available; and (3) the percentage and dollar amount financed by nongovernmental sources. The provision frames what counts as a covered communication (including RFPs and solicitations) and draws a single narrow exception for communications under 280 characters. Practically, agencies and recipients will need standard language and calculation methods to populate those three data points consistently across varied documents.
Certification in performance progress reports
Mandates that recipients include a certification in their performance progress reports indicating whether they complied with the disclosure requirements. This ties compliance into routine grant and program reporting cycles, creating a paper trail. The bill does not prescribe independent verification procedures for those certifications, so agencies will need to decide whether to audit or accept them at face value.
OMB compliance reviews and public findings
Directs the OMB Director to perform annual reviews of a random sample of public communications issued by agencies and recipients to assess compliance, and to make the review findings public. The sampling requirement gives OMB discretion on scope and sample size, and publicizing results creates transparency about implementation, but the statute does not specify sanctions or remedial steps for identified noncompliance.
Anonymous public reporting mechanism
Requires OMB to deliver, within one year, an anonymous public mechanism for reporting communications that fail to comply with the disclosure requirements. The reporting tool must accept either the noncompliant communication or its web location and identifying information about the federally funded program. This creates a public-facing avenue for third parties—journalists, watchdogs, citizens—to flag noncompliance, but it also raises questions about handling volume, frivolous tips, and privacy.
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Explore Government in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Taxpayers and the general public — gain clearer, immediate information in press releases and solicitations about how much of a project is federally funded, improving fiscal transparency without digging through budget documents.
- Journalists, watchdogs, and policy researchers — receive standardized, public data points (percentage and dollar amounts) that make it easier to compare and analyze funding mixes across programs and identify potential misuse or duplication of federal funds.
- Congressional oversight and committee staff — get a new, statutory stream of evidence (OMB sampling reports and public tip submissions) to support hearings and investigations into federal spending.
- Procurement participants and potential contractors — obtain clearer upfront information in solicitations about federal funding levels and cost-share expectations, which aids bid preparation and financial planning.
Who Bears the Cost
- Federal agencies — must adapt communications, train staff, and develop processes to calculate and publish funding percentages and dollar amounts across many documents, increasing communications and program management workload.
- Grant recipients, states, local governments, academic institutions, and nonprofits — face new compliance duties to include disclosures in public materials and to certify compliance in progress reports, which could be administratively burdensome for smaller entities.
- Office of Management and Budget — must design and operate the anonymous reporting mechanism and carry out annual random-sample reviews, requiring staff time and possibly new technical resources without an explicit appropriation in the bill.
- Communications teams and contractors — need to revise templates and may have to withhold or rework short-form messaging to avoid the 280-character exclusion or to ensure required disclosures are present and accurate.
Key Issues
The Core Tension
The bill forces a trade-off between greater public accountability—by embedding clear funding facts into everyday public materials—and the administrative, operational, and confidentiality costs of producing accurate, standardized disclosures for complex funding arrangements. Enhancing transparency improves oversight but risks imposing burdens that are especially meaningful for smaller recipients and could complicate routine public communications.
The bill leaves several practical questions unresolved. First, calculating the 'percentage of the total costs' can be complex for multi-year, multi-source projects that include in-kind contributions, indirect cost allocations, or conditional funding.
The statute does not define whether to use total project lifecycle cost, annualized cost, obligated funds, or authorized amounts, so agencies will need consistent guidance. Second, the bill requires a certification in performance reports but contains no verification standard or penalty for false certifications; enforcement appears to rely on OMB sampling, public reporting, and existing oversight authorities rather than a built-in sanctioning mechanism.
Operationally, the anonymous reporting tool creates potential for both useful crowd-sourced oversight and burdensome noise. OMB will need processes to triage and verify tips, which could strain resources if the mechanism attracts high-volume submissions.
The 280-character exemption also creates a behavioral incentive: communications teams may avoid short social posts that omit disclosures or conversely avoid posting short alerts for fear of noncompliance, with implications for agencies' public engagement strategies. Finally, the requirement to state nongovernmental financing raises confidentiality concerns for private partners who prefer nondisclosure of their contributions or for procurements that include commercially sensitive financing structures.
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