Comment from Melwood, Inc.

Melwood, Inc.OtherAdvocacy
Summary: Melwood, an organization advocating for and employing people with disabilities, provides mixed feedback on the proposed rule. They support the Commission's rationale for subcontracting limits but express concern that the specific 25% and 10% thresholds may hinder growth in new business lines. Additionally, they suggest implementing a tiered fee structure based on contract lifecycle and advocate for increased transparency in how Program Fees are reported and utilized.
Attached are Melwood's comments in the NPRM regarding the CNA fee subcontracting within the AbilityOne Program.

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