Comment from Central Association for the Blind and Visually Impaired

Summary: The Central Association for the Blind and Visually Impaired (CABVI) provides mixed feedback on the proposed rule. While they support the clarification of the Program Fee as an allowable expense and the modernization of subcontracting rules, they oppose the requirement to structure agreements under 2 C.F.R. part 200 (Uniform Guidance) due to concerns over regulatory burden and lack of economic analysis.