Who is a member?
Our members are the local governments of Massachusetts and their elected and appointed leadership.
Honorable Russel T. Vought
Director Office of Management and Budget
725 17th St. NW
Washington, DC 20503
Re: OMB-2026-0034, Office of Management and Budget (OMB) Regulation for Federal Financial Assistance
Dear Director Vought,
The Massachusetts Municipal Association writes to share comments on the proposal to revise the Office of Management and Budget Guidance for Federal Financial Assistance located in Title 2 of the Code of Federal Regulations (CFR), subtitle A. The MMA is a nonprofit, nonpartisan association of cities and towns, representing all 351 communities in Massachusetts.
We appreciate the important work of the OMB and the stated goals of the proposal to improve transparency and accountability while reducing the regulatory burden on federal grant administrators and grantees. We thank you for your focus on streamlining government processes to benefit communities across the nation. Although the proposal conceptually could decrease burdens on federal offices, we are deeply concerned that the proposed changes would increase regulatory burdens on municipalities while destabilizing critical federal funding resources. Cities and towns of all sizes and politics across Massachusetts are in need of stable federal funding processes and opportunities.
We urge you to reconsider the proposed changes to ensure the regulations do not unintentionally contribute to unwieldy government processes and a climate of uncertainty. We further request that the deadline for public comment be extended to ensure that all affected parties are aware of the proposed changes and able to weigh in.
Increased Administrative Burden on Communities
Many of our 351 municipalities operate without formal grant writers or administrators and rely on a small number of staff to perform all varieties of municipal functions. Creating additional regulatory burdens through additional steps in the compliance and reimbursement process without adding additional resources or funding will be particularly problematic for these municipalities. Though not the intent, we expect many of the changes proposed by the OMB would increase this administrative challenge locally. This factor should be examined more closely while allowing additional time for those affected by this burden to weigh in.
For example, requiring all payment requests to include written justifications describing the purpose of each payment and the specific work it supports would necessitate significant additional time and energy, requiring staff to spend substantial additional hours justifying each and every grant payment. This is in addition to already spending requisite time and resources applying for the initial grant and managing the project. Many smaller municipalities would simply be unable to fulfill this requirement, and be forced into noncompliance or inability to even apply for such a grant, resulting in an untold number of projects incomplete, and leaving smaller towns even further behind.
Additionally, granting agencies the ability to add or remove conditions during the period of performance based on various unspecified “risk” and “other factors,” without providing guidance on what those factors are, is extremely problematic. Not only does this create uncertainty, as discussed below, but changing conditions during a grant performance period would be incredibly difficult to manage, and could double or even triple the amount of administrative time a grant manager spends, as they adjust to various changing conditions. The increased burden would impact all cities and towns, but would especially overburden our smallest and less-resourced communities.
Contributing to Uncertain and Unwieldy Federal Funding
We believe that federal funding needs to be clear, certain and predictable so that municipalities can understandably rely on this key funding source. Unstable and unpredictable federal funding results in unstable local budgets and can create additional cost burdens on municipalities and, in turn, their taxpayers. In addition to the potential administrative burden, uncertainty in funding streams makes it difficult to find matching funds and attract outside partners, including commercial business leaders. This uncertainty creates a cascade of negative impacts, stressing municipal budgets and relationships, and disrupting local and regional economies.
Allowing agencies to terminate a grant award during their performance period creates drastic uncertainty and puts additional and unnecessary stressors on subcontractors and other engaged stakeholders. While this type of uncertainty would be problematic for municipalities, it would be acutely felt in those communities using a town meeting form of government, where local residents must meet once per year to set budgets. Having to alter these budgets mid-project is not a simple process, and any mid-year adjustments would require convening a special town meeting, which requires funding to run. Local officials in these municipalities cannot simply reallocate funds or approve emergency amendments at a standard weekly meeting. Instead, they would be required to issue formal warrants, notify the public weeks in advance, and gather a citizen quorum to address a sudden unexpected federal funding gap.
Again, the negative impact would fall most heavily on our small towns. These communities will have particular difficulty when faced with a cash flow crisis created by the sudden termination of a grant award. Aside from the logistical process of meeting to create a new budget, small towns lack the broad tax base and large financial reserves with which to absorb a deficit. This would be further exacerbated by the proposal to eliminate fixed amount awards and subawards.
Unequal Enforcement in Federal Grant Making
Finally, the MMA strongly believes that federal grantmaking should be consistent, transparent and accessible to all eligible communities, firmly grounded in objective policy criteria. Many of the proposed OMB changes give too much discretion to appointed agency staff, while requiring applicants and subcontractors to comply with ever-changing executive orders and expressed priorities. For example, the proposal to allow agencies to consider an applicant’s “history of questionable practices” when making grant determinations, without providing a definition of what such practices might be considered, gives significant leeway to agencies and is ripe for unequal enforcement. Such a practice would also inflict considerable untenable oversight burden to municipalities over subcontractors.
We strongly urge you to revise the proposed rules to limit the volatility of federal funding programs that could compromise the integrity of such resources.
Conclusion
The MMA understands the intended goals of the OMB to create greater transparency while simplifying processes for federal grantmaking. However, the current proposed changes only add to already burdensome administrative processes and contribute to a climate of uncertainty and confusion. We urge the OMB to reconsider these provisions and extend the deadline to allow consideration of additional comments from the wide array of stakeholders who will be affected.
Sincerely,
Adam Chapdelaine
MMA Executive Director and CEO