SB 100: Federalism Revisions - Utah

Substitute #2 → Substitute #3 · 5 edits

MODERATE

This bill substitutes a new version of SB 100 that updates the Federalism Commission's duties and reporting requirements. The primary changes involve correcting the House Sponsor's name, adjusting the effective date for education entities to May 6, 2026, and clarifying the specific website where federal guidance letters must be published. The bill also refines the definitions of 'education entity' and 'federal guidance letter' to ensure clearer compliance standards for state agencies.

Scope change

The scope of applicability for education entities regarding the publication and reporting of federal guidance letters was extended to begin on May 6, 2026, rather than the previous July 1, 2025 date.

TECHNICAL

The House Sponsor's name was changed from 'LONG TITLE' to 'Ken Ivory'.

TIMELINE

The deadline for education entities to start publishing and reporting federal guidance letters was moved from July 1, 2025, to May 6, 2026.

REQUIREMENT

The specific statewide website where federal guidance letters must be published was changed from the 'Utah Open Data Portal' to the 'Public Notice Website' created in Section 63A-16-601.

DEFINITION

The definition of 'education entity' was updated to explicitly list the State Charter School Board and clarify references to local school boards and charter school governing boards.

The definition of 'federal guidance letter' was refined to clarify that it includes nonbinding statements of general applicability but excludes specific communications about confidential tax information.

Substitute #1 → Substitute #2 · 5 edits

MODERATE

This bill revises the Federalism Commission's duties to include protecting a trademark for a state-led federalism organization and updates the curriculum for federalism training to include the Ninth and Fourteenth Amendments. It also extends the requirement for state agencies to publish and report federal guidance letters to education entities, shifting their effective date to May 6, 2026, and requires annual reporting of these letters to the Legislative Management Committee.

Scope change

The bill expands the scope of the Federalism Commission's work by adding trademark protection duties for a state organization and broadens the definition of required training topics. It also expands the applicability of federal guidance letter reporting requirements to include education entities.

REQUIREMENT

Added a requirement for the Attorney General to register and protect a trademark for a state-led national federalism organization.

Modified the federalism training curriculum to include the Ninth and Fourteenth Amendments and updated descriptions of state powers.

Added a requirement for the Federalism Commission to report annually to the Legislative Management Committee regarding federal guidance letters.

ELIGIBILITY

Extended the requirement to publish and report federal guidance letters to education entities, with a later effective date of May 6, 2026.

TECHNICAL

Updated the Utah Code sections affected list to include Section 53H-4-703.

Amended 1/26/2026 11:01:272 → Substitute #1 · 3 edits

MINOR

The bill text was reformatted to remove legacy markup symbols, correct a typo regarding 'United States Senator', and update the effective date in the title from 2026 to 2025. The substantive policy content, including requirements for agencies to report federal guidance letters and the Federalism Commission's duties, remains unchanged.

TECHNICAL

Removed legacy markup symbols (e.g., 1...1) and formatting artifacts from the text.

Corrected a typo in Section 63C-4a-303(3)(c) by removing an erroneous repetition of 'Senator' and 'Representative'.

TIMELINE

Changed the effective date listed in the title from 2026 to 2025 to match the actual effective date in Section 4.

Amended Excerpts 1/26/2026 11:01:272 → Amended 1/26/2026 11:01:272 · 5 edits

MODERATE

The bill replaces a section of the Utah Code that previously dealt with federal guidance letters with a new, comprehensive framework for the Federalism Commission. This change shifts the focus from simple publication requirements to a robust process where the commission must actively evaluate federal laws for impacts on state sovereignty, contract third parties to monitor these laws, and provide detailed reports to legislative committees.

Scope change

The scope expanded from a specific administrative task (publishing guidance letters) to a broad mandate for the Federalism Commission to evaluate, monitor, and report on federal laws affecting state sovereignty and the principles of federalism.

SCOPE

The specific requirement to publish federal guidance letters on state websites and data portals was removed and replaced with a broader mandate for the Federalism Commission to evaluate federal laws.

REQUIREMENT

New requirements were added for the commission to contract with Utah institutions of higher education to monitor federal law and report findings on implications for state sovereignty.

The commission is now required to submit annual reports to interim legislative committees regarding federal laws that impact federalism or state sovereignty.

ENFORCEMENT

New procedures were established allowing the commission to request information from U.S. representatives, demand responses from federal entities, and request meetings to discuss federal law evaluations.

DEFINITION

The term 'interim committee' was explicitly defined to clarify which legislative bodies receive the commission's reports.

Enrolled → Amended Excerpts 1/26/2026 11:01:272 · 3 edits

MINOR

The bill was amended to clarify the specific website where state agencies must publish federal guidance letters and to streamline the reporting process by removing the requirement to send copies to the Legislative Management Committee. Additionally, a technical correction was made to the section number for the Utah Open Data Portal Public Notice Website.

Scope change

The scope of reporting requirements was narrowed by removing the obligation for state agencies to transmit copies of federal guidance letters to the Legislative Management Committee, while retaining the requirement to report to the Federalism Commission.

REQUIREMENT

Removed the requirement for state agencies to transmit copies of federal guidance letters to the Legislative Management Committee, keeping only the requirement to submit an electronic report to the Federalism Commission.

TECHNICAL

Corrected the section number for the Utah Open Data Portal Public Notice Website from 63A-16-107 to 63A-16-601.

Adjusted the text to clarify that the report must be submitted to the commission, replacing the previous instruction to transmit a copy.

Introduced → Enrolled · 2 edits · Mar 17, 2026

MINOR

The bill was updated from an introduced draft to an enrolled version, finalizing the text for passage. The primary substantive change is the addition of a provision allowing the Federalism Commission to register and use certain federalism-related trademarks. Other changes include minor formatting corrections, such as fixing a typo in the House Sponsor's name and adjusting line breaks for clarity.

Scope change

The bill's scope was slightly expanded to include the registration and use of federalism-related trademarks, while the core requirements for publishing federal guidance letters and evaluating federal laws remain substantively the same.

REQUIREMENT

Added a new provision authorizing the Federalism Commission to register and use certain federalism-related trademarks.

TECHNICAL

Corrected the House Sponsor's name from 'LONG TITLE' to 'Ken Ivory' and fixed various formatting inconsistencies and line breaks throughout the document.

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