Comment on OMB-2026-0034-0001
Cedar Valley ServicesSupportGovernment
Summary: A representative of a small rural public transit agency argues that requiring prior written approval for every association membership is an unnecessary administrative burden. They request that memberships and subscriptions be allowed through the standard budget narrative process, as these associations provide essential technical guidance, compliance support, and peer-to-peer problem-solving.
[200.454] I operate a small public transit agency in a rural setting, and want to convey that association memberships are not a perk, but rather a practical source of guidance on all things compliance, technical education, standards in our industry, and most importantly peer-to-peer problem solving; many grant-funded fields rely on associations to assist with the quick interpretation of rule changes, offer up sample policies, model practicing, and continuing education (like conferences and webinars), and requiring prior written approval for every membership is a burden for both recipients and federal agencies alike. The OMB should allow membership and subscriptions when they directly support the field and award performance along with compliance and other areas that can be difficult for agencies to keep track of. Case-by-case approvals after an award is made will simply reduce the quality of the respective organization / field and lead to long-term challenges for people who have relied on these associations for years. Please consider allowing memberships and subscriptions to be approved through the budget and budget narrative process and give agencies like ours the ability to maintain our wealth of knowledge by continuing to utilize resources readily available to us.