Comment on OMB-2026-0034-0001
Cedar Valley ServicesOpposeAdvocacy
Summary: A small non-profit organization in the public transportation sector opposes the proposed rule because it imposes burdensome requirements on smaller agencies. They argue that the rule makes it difficult to attend timely training and suggest that oversight should focus on the reasonableness and allocability of conference expenses rather than requiring specific event names at the time of application.
[200.432] As a smaller non-profit who works in public transportation, we regularly use conferences as a way to stay up to date with all of the changes in our field, and it gives our staff a great opportunity to access professional development that makes them, our agency, and our services better for our communities and our passengers. The proposed rule would add new requirements that would be burdensome to smaller agencies like ours, and make attending relevant and timely training seminars and conferences difficult, especially when they're announced after the award is issued; we would like to see the existing regulatory oversight be used, even if more stringent, to ensure it fits the scope of the award and is relevant to the field we work in. We feel that OMB should focus on the reasonableness of the conference, ensuring it is allocable and connected to award performance as opposed to knowing the name or if the event even exists at the time of applying for the award (usually 12-18 months before conferences can even be planned). Please let recipients document attendance through agendas and other descriptions of sessions, etc. to ensure it meets the development standards needed for federal funding.