Comment Submitted by Clare Housing

Re: Regulation Changes to Docket Number OMB-2026-0034, Office of Management and Budget (OMB) Regulation for Federal Financial Assistance, RIN Number 0348-AB8 My name is Phoebe Trepp, and I am the Executive Director of Clare Housing. For the past 40 years, Clare Housing has provided deeply affordable housing with services for people living with HIV. Through a federal program, HOPWA (Housing Opportunities for People Living with HIV/AIDS), our services are directed to people living with HIV who have low incomes. Clare Housings programs provide HIV-care/prevention and address homelessness. Our HIV housing programs are driven by research outcomes, needs assessments, as well as specificity to populations with the least access to healthcare and housing. People experiencing homelessness are 16 x more likely to have HIV than those who are housed. We know that housing is the foundation for people living with HIV to access their medication, and to become Undetectable (meaning they are not able to transmit HIV because their viral loads are so low). Once housed, over 90% of our residents achieve an undetectable status. Through this process of becoming virally suppressed, our organization prevents HIV-transmission alongside providing care to those who already have HIV. In addition to housing, we also provide health and medical services. In addition to HIV management, we provide support for other chronic illnesses, end of life care, substance use treatment, and reintroduction to community life. Federal grants that are responsive and specific to communities with the highest rates of health and housing barriers are data-driven and remain necessary. With the proposed changes as we currently understand them, we would not be able to create programs that are designed to meet long-term and urgent needs, including our aging populations of people living with HIV (over half of people living with HIV are over 50), people under the age of 30 (where the majority of new transmissions are occurring), HIV outbreaks in specific populations and locations within our region, indigenous and native people, and black and brown people in our community. The proposed changes to the OMB Guidance for Federal Financial Assistance would harm the people our organization aims to serve, by preventing specific ongoing investments in HIV Housing across the country. The proposal will deter nonprofits from deploying the direct and innovative approaches to improve the housing, health, and future of our communities most impacted by inequities found in every state of the US. Threatening important congressionally funded federal programs that help address longstanding racial, social, and other disparities, and investing in services for historically underserved communities will impact rural, urban, and suburban communities nationally. My organization strongly opposes the proposed changes and the impact they will have on the people we serve and everyone in our community who will be further impacted by new HIV transmissions. We envision a housed and healthy future for all community members, which requires the flexibility to respond to specific needs within unique communities. Thank you for considering this input.