State/Local Orgs Demand OMB Exentend Comment Period
As the July 13 deadline date for comments to the Office of Management and Budget’s (OMB) proposed rule to amend the regulations under Title 2 of the C.F.R., including the uniform guidance (2 C.F.R. Part 200), fast approaches, we’re learning that the need for more time to submit responses is becoming increasingly more critical, and key stakeholders are teaming up to urge OMB to extend the comment period.
In a recent letter to OMB Director Russell Voight, 10 organizations representing local and state government concerns sought a 45-day comment period extension, noting that OMB’s provided 45-day window “is insufficient to meaningfully analyze and respond to a rulemaking of this scope and consequence.” This language was similar to issues brought up by COGR in its earlier request to extend the comment period to 90 total days.
“State and local governments are not only recipients of federal grants — we are the primary implementing layer through which federally appropriated funds reach communities for public safety, public health, transportation, housing, workforce development, child welfare, and emergency management,” the letter explains. “The proposed rule’s changes will affect state and local government program design and service delivery in substantial ways that require careful operational review before the comment period closes. Adequate time for stakeholder engagement is essential to ensure that comments submitted reflect the on-the-ground realities of implementing federal programs at the local level. A 45-day extension would enable state and local governments, and our subrecipient partners, to provide OMB with the substantive input that a rulemaking of this magnitude warrants.”
While we organizations acknowledged that OMB is aiming to issue a final rule by Oct. 1, they contended that “a more complete record will serve the interests of both the public and the agency and help ensure that policy changes of this magnitude are informed by a full understanding of their practical consequences.” Organizations signing the letter were the National Association of Counties, National League of Cities, U.S. Conference of Mayors, National Conference of State Legislators, Council of State Governments, International City/County Management Association, Government Finance Officers Association, National Association of Development Organizations, Association of Metropolitan Planning Organizations, and the National Association of Regional Councils.
As of now, there has been no indication from OMB that it would grant such an extension, regardless of the numerous stakeholder requests.
We also have learned that when the proposed rule was issued on May 29, not only was it the first time grants stakeholders saw what changes were included, it also was new to most federal agency personnel. Speaking to members of the D.C. Chapter of the National Grants Management Association on Tuesday, a former federal official who served in working groups that partnered with OMB on revisions to the uniform guidance that were released in 2020 and 2024, said that federal agencies worked collaboratively with OMB on those two updates and provided multiple rounds of input.
“This time, agencies are seeing this at the same time as the public,” she said. She added that since the current proposed rule aims to change 2 C.F.R. Part 200 from its historical stance as “guidance” that is adopted into fedearl agency regulations along with agency exceptions into what OMB would call the “uniform grants regulation” that federal agencies must adopt directly, “it short-circuits the typical rulemaking process.” She explained that agencies should be able to adopt the uniform guidance requirements into their own regulations to effectively designate to recipients where deviations exist by statute. “Agencies really need to have [the current] rulemaking process rather than having [the proposed uniform grants regulation] forced down on them because without that, you lose the important oversight related to what the statutory requirements really are,” she added.
As of July 1, some 44,000 comments have been submitted to Regulations.gov on this issue and that number will continue to grow exponentially. Time is running out on the comment period so all grantees are encouraged to submit their comments today!
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