Members Encouraged to Submit Individual Comments
As PHADA finalizes comments on the Proposed Rule from the Office of Management and Budget (OMB) on Regulations for Financial Assistance, members are encouraged to submit individual comments before the July 13 deadline.
As previously reported in the Advocate, the proposed rule would make significant changes to 2 CFR 200 and convert this guidance into regulation, and would undermine its stated goals to increase transparency, accountability, and oversight while reducing administrative burdens. The proposal, which covers over 40 federal agencies including HUD, would consolidate authority at OMB contrary to Congressional authorizations, insert political judgement into grant management and oversight, and substantially increase reporting and documentation burdens for both administering federal agencies and funding recipients.
The proposed rule and link to comment can be found at Regulations.gov. PHADA’s Issue Brief on the proposed rule can be found here.
Individualized comments are encouraged. In addition to the concerns raised in the issue brief, members may want to consider the following:
- The 45-day comment period is too short to provide meaningful comments on this lengthy rule and violates HUD’s own regulations requiring at least a 60-day comment period.
- The proposed rule would increase administrative burdens and risk delays in federal funding by requiring political appointees to approve every award and agreement, allow discretionary terminations or suspension, and require HUD pre-approval of memberships, subscriptions, and conferences.
- The proposed rule inserts political requirements and determinations beyond its authority, establishing undefined standards on which terminations can be made including not advancing administration priorities, not in the national interest, or risking “reputational harm” to the federal government, federal agency, or local entity.
- The proposed rule is unclear about what federal funding is covered. Most relevant, it is unclear if payments made under Annual Contributions Contracts with local housing authorities for the Public Housing and Housing Choice Voucher programs would be covered.
Members seeking additional information may want to review materials from other organizations as well, such as this webinar and slide deck from the National Association of Counties (NACo), or this Comment Guide from the National Council of Nonprofits.