Associations Seek Comment Period Extension for Proposed Uniform Guidance Revisions

Even though there are still four weeks left to comment on the Office of Management and Budget’s (OMB) proposed revisions to the uniform grant guidance, as well as other potential revisions to guidance in Title 2, Subtitle A of the Code of Federal Regulations, some groups are already seeking more time to comment. And rightly so, these proposed revisions are extensive and complex.

In a recent joint letter to OMB officials, eight higher education associations representing research universities and related institutions requested that OMB extend the 60-day comment period for another 30 days, whereby the comment due date would be April 22, rather than the current deadline of March 23. These eight associations are the Council on Governmental Relations, Association of Public and Land Grant Universities, Association of School and Programs of Public Health, National Association of College and University Business Officers, American Council on Education, Association of American Medical Colleges, Association of Public Universities and the Independent Research Institutes.

The groups stated that the proposed changes have “the potential to make a significant contribution to the quality and effectiveness of the research environment.” However, they noted that “while we understand the sense of urgency OMB has to finalize the revisions, experience and precedent tells us that a 30-day extension to allow for more thorough and thoughtful comments will add value to the final product and allow for more productive coordination across the higher education community.”

The letter explained that the extra time will allow the groups to better assess the proposed revisions’ “impact on burden, unintended consequences and … how the revisions intersect with the balance” between the uniform guidance and the current version of the Frequently Asked Questions pertaining to the uniform guidance. “This is not a task to be taken lightly, and if we are given the opportunity to do the same quality review that we have done in the past, the entire grantee community, both federal and non-federal entities, will benefit,” the letter added.

The associations also identified that provisions in §200.109 require the uniform guidance to be reviewed every five years, and that “even if OMB intends to be more agile in future revisions, it is not assured we will have the opportunity to comment until the year 2025 — our community feels strongly that our request for a 30-day extension is both reasonable and a wise investment to ensure the best version” of the uniform guidance is developed.

We wouldn’t be surprised if more groups come forward asking for an extension of the deadline. If such an extension is granted, we’ll be sure to let the grant community know. Otherwise, take a look at the proposed changes now and prepare your comments by March 23.

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