The Cost Openness and Spending Transparency (COST) Act adds a new section to 31 U.S.C. requiring agencies and any individual or entity carrying out programs paid in whole or in part with federal funds to disclose the percentage and dollar amount of federal funding and the percentage and dollar amount provided by nongovernmental sources in documents that describe the project. The requirement extends to statements, press releases, RFPs, bid solicitations, and similar materials, with a specific carve-out for communications of 280 characters or fewer.
The bill also makes OMB responsible for annual compliance sampling and publicizing results, and it directs OMB to create a public, anonymous reporting mechanism within one year for alleged noncompliant communications. For compliance officers and program managers, the bill standardizes a public “price tag” on federally supported work but raises immediate implementation questions about scope, calculation methodology, proprietary data, and enforcement mechanisms.
At a Glance
What It Does
Adds 31 U.S.C. §1356 requiring clear disclosure — in most public materials that describe a federally supported program, project, or activity — of (1) the percentage of total costs paid with Federal funds, (2) the dollar amount of Federal funds, and (3) the percentage and dollar amount financed by nongovernmental sources. It exempts communications of 280 characters or less but requires a certification about compliance with respect to such short communications.
Who It Affects
Executive and independent regulatory agencies, state and local governments that administer federally supported projects, grant recipients (including research institutions), contractors, and vendors who issue press releases, solicitations, or project descriptions concerning federally funded work.
Why It Matters
The bill formalizes a cross-government requirement to label federal financial participation, shifting disclosure norms for grants, contracts, and public communications; it creates OMB-led monitoring and a public tip line rather than a statutory penalty structure, making implementation and administrative burden the practical policy levers.
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What This Bill Actually Does
The COST Act inserts a new statutory requirement into the federal financial management code. Under the added 31 U.S.C. §1356, any agency or any individual or entity performing a program, project, or activity that is funded in whole or part by federal funds must include three pieces of cost information in any document that describes the work: the percentage of total cost financed by the federal government, the dollar amount of federal funds provided, and the percentage and dollar amount financed by nongovernmental sources.
The listed examples — statements, press releases, RFPs, and bid solicitations — are illustrative but the statute uses a broader phrase, “other document describing” the program, which could sweep in many forms of public communication.
The statute carves out communications of 280 characters or fewer from the disclosure requirement, but it simultaneously requires recipients to include in their performance progress reporting a certification indicating whether they complied with subsection (b) “with respect to communications containing not more than 280 characters.” That creates a compliance reporting obligation tied to short-format communications even though those messages are exempt from the disclosure requirement itself. The bill does not create an express civil or criminal penalty for failure to include the disclosures; instead it relies on an administrative monitoring regime and public reporting.Practically, the Office of Management and Budget (OMB) must annually review a random sample of public communications from agencies and recipients to assess compliance and publish the findings.
OMB must also, within one year, build and publish a mechanism for the public to anonymously report communications that appear noncompliant; that reporting tool must accept the noncompliant communication or a link to it and identifying information about the program or project. The statute applies to executive agencies (as defined in 5 U.S.C. §105) and independent regulatory agencies (44 U.S.C. §3502), and explicitly names state and local governments and federal research grant recipients as covered examples.Because the bill focuses on disclosures in public materials rather than creating a new grant condition with a defined enforcement penalty, agencies and recipients will need to translate the statutory language into operational guidance: how to calculate total project costs (including in-kind or indirect contributions), when a document “describes” a project, how to handle proprietary or competitively sensitive cost information, and how to document compliance for the required certification.
OMB will carry the administrative workload of sampling, publishing results, and standing up the reporting platform — functions that will require staffing, rulemaking or guidance, and potential coordination with grant-making agencies.
The Five Things You Need to Know
The bill adds 31 U.S.C. §1356, requiring disclosure in any document that describes a federally supported program of (a) federal share as a percentage, (b) federal dollar amount, and (c) nongovernmental share as percentage and dollar amount.
The disclosure requirement applies to agencies and any individual or entity carrying out programs using federal funds, explicitly including State and local governments and recipients of federal research grants.
Communications that are 280 characters or fewer are excluded from the disclosure requirement, but recipients must still certify in performance progress reports whether they complied with the disclosure requirements with respect to such short communications.
OMB must annually review a random sample of public communications for compliance and publicly release the findings of that review.
Within one year of enactment, OMB must create a public, anonymous reporting mechanism for alleged noncompliant communications that accepts the noncompliant communication (or its location) and identifying information about the program or project.
Section-by-Section Breakdown
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Short title
Designates the act as the "Cost Openness and Spending Transparency Act of 2026" or the "COST Act." This is purely nominal but signals Congressional intent to prioritize cost labeling in public-facing communications.
Who is covered
Defines ‘agency’ to include Executive agencies under 5 U.S.C. §105 and independent regulatory agencies under 44 U.S.C. §3502. The provision also signals that the statute reaches ‘any individual or entity’ carrying out federally funded work — the text explicitly references state and local governments and recipients of federal research grants — creating a broad coverage sweep beyond core federal agencies.
Substantive disclosure duty
Imposes the core obligation: in any statement, press release, RFP, bid solicitation, or “other document describing” a federally funded program, the discloser must state the percentage of total costs financed by Federal funds, the dollar amount of Federal funds, and the percentage and dollar amount financed by nongovernmental sources. Practically, agencies and recipients must build processes to calculate and publish both percentages and dollar figures tied to a project’s total cost. The statutory phrasing is broad — the operational boundary for “other document describing” will determine how far the requirement reaches into routine communications.
Certification tied to short communications
Requires that recipients include in performance progress reporting a certification indicating whether they complied with subsection (b) regarding communications containing not more than 280 characters. This introduces a reporting obligation that references short-format communications even though those messages are exempt from the disclosure duty, creating a potentially confusing compliance checkpoint that agencies will need to clarify in guidance.
OMB compliance review and publication
Directs the Director of OMB to annually review a random sampling of public communications from agencies and recipients to assess compliance with the disclosure rules and to publish the findings. The provision assigns OMB the role of monitoring and public accountability rather than a department-specific enforcement mechanism; agencies will need to coordinate with OMB on sampling frames and data access for reviews.
Anonymous public reporting tool and statutory placement
Requires OMB to build, within one year, a mechanism enabling anonymous public reporting of communications that appear noncompliant; the report must include the noncompliant communication or its location and identifying information about the program, project, or activity. The bill also amends the subchapter table of sections to list the new §1356. The reporting tool will be a public-facing oversight channel that agencies must monitor and potentially respond to.
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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 public — will gain clearer, standardized public information tying projects to federal dollar amounts and shares, making it easier to see how federal funds leverage nonfederal resources.
- Watchdog organizations and journalists — receive a statutory basis to demand cost information and a formal, anonymous reporting channel to flag possible nondisclosures.
- Policymakers and appropriations staff — benefit from more consistent publicly visible cost attribution when evaluating programs and budget priorities.
Who Bears the Cost
- Federal agencies and OMB — must develop guidance, run annual compliance sampling, and create/maintain the anonymous reporting mechanism, adding administrative workload and likely requiring new resources.
- Grant recipients, contractors, and small subgrantees — must calculate and publish percentage and dollar breakdowns across many public communications and include certification in performance reports, increasing compliance tasks and possibly legal review to protect proprietary information.
- State and local governments implementing federally supported projects — will need to surface cost-sharing details publicly, which could complicate intergovernmental agreements and reveal local funding strategies or sensitive financial arrangements.
Key Issues
The Core Tension
The bill pits a clear public-interest goal — making taxpayer contributions visible — against operational realities: producing accurate, project-level price tags is administratively costly, may expose proprietary or sensitive details, and requires definitional and accounting choices that can materially change the meaning of the disclosed figures; clarity and enforceability will depend on OMB’s forthcoming guidance and resourcing.
The statute’s language raises immediate implementation and legal questions. First, the phrase “other document describing the program, project, or activity” is broad and could encompass materials that agencies and recipients do not currently classify as public project descriptions; agencies will need to draw practical lines in guidance.
Second, the 280-character exception paired with a certification requirement about compliance for such short communications is internally inconsistent as written: exempting short communications from the disclosure rule but forcing a certification about those communications creates a reporting obligation without a clear substantive duty, which will require OMB interpretation or corrective drafting.
Operationally, the bill gives OMB monitoring responsibility but sets no civil or administrative penalties for nondisclosure; enforcement will depend on publicity, interagency pressure, and possible grant-management consequences. Determining the numerator and denominator for percentages raises technical headaches: projects with phased funding, in-kind contributions, matching funds, indirect costs, and multi-source financing will need consistent cost-accounting rules; absent those rules, disclosures could be misleading.
There are also confidentiality concerns: contractors and grantees commonly protect cost breakdowns as proprietary—publicizing dollar amounts or specific nongovernmental contributions could harm competitive positions or expose sensitive partner information. Finally, the anonymous reporting tool could improve oversight but also invites frivolous or politically motivated complaints; OMB will need procedures to triage reports without overburdening agencies or chilling legitimate communications.
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