Comment from VisionCorps
VisionCorpsOpposeAdvocacy
Summary: VisionCorps, an organization supporting employment for people who are blind, opposes the proposed requirement to structure agreements with central nonprofit agencies as cooperative agreements governed by 2 C.F.R. part 200. They argue that this change creates unnecessary regulatory burdens and lacks sufficient economic analysis regarding its impact on program fees and employment outcomes.
VisionCorps respectfully submits this comment in response to the U.S. AbilityOne Commission’s proposed amendments to 41 CFR 51-3.5 and 41 CFR 51-4.4. We appreciate the Commission’s efforts to codify statutory requirements regarding cooperative agreements and to clarify subcontracting rules. However, we are concerned that any reduction in the effective CNA program fee, or any fee structure that constrains NIB’s ability to perform shared mission functions, would have significant negative impacts and unintended consequences for VisionCorps and similarly situated NPAs.