Comment on OMB-2026-0034-0001

Mental Health Partnerships (MHP), a 75-year-old nonprofit organization in Pennsylvania, and an affiliate of Mental Health America, strongly opposes the proposed changes to the Office of Management and Budget's Uniform Guidance. MHP collaboratively builds hope and promotes the well-being of people in recovery through innovative, peer-centered advocacy, learning, and services. As a nonprofit, we are the beneficiaries of federal grants that support our work, and the proposed rule would make it more difficult and costly for nonprofits like ours to pursue federal funding. What is most concerning is that the proposal allows federal agencies to determine discretionary federal awards based on partisan ideology rather than community needs or congressional intent (§ 200.205). Federal grants are awarded based on an organization ‘s capacity to fulfill the needs of the grant and other important criteria. Political ideology should not be one of the criteria that is used to decide on the allocation of taxpayers’ dollars. The rule would also deter nonprofits such as MHP from pursuing federal funds that help people face mental health challenges and substance use disorders. The unprecedented risks this rule introduces for nonprofits could lead to disruptions in essential services, including homelessness outreach and support services for people living with mental health diagnoses. For example, the new rule (§ 200.205) creates a preference for discretionary awards to be given to grantees with lower indirect cost rates. This would essentially shut out organizations such as MHP that do not have the financial resources to absorb unreimbursed indirect costs. This new rule would also allow the administration to terminate a grant without cause or justification (§ 200.211, § 200.340, § 200.341, § 200.342, § 200.343). For Mental Health Partnerships, this could mean losing funding for rapid rehousing for our Delaware County participants resulting in an abrupt loss of housing and support, stability and health, without ever knowing why. Grant funding decisions must not become a political tool that shifts with every change in administration. They should be guided by experts in the field as well as by the priorities set by Congress, not by ideology, and not at the expense of the people who depend on these services every day. We urge OMB to withdraw these proposed changes to the Uniform Guidance.