Comment on OMB-2026-0034-0001

To Whom It May Concern: On behalf of New Gateways, Inc., a Michigan nonprofit organization providing community-based skill building, transportation, and enrichment services to adults with intellectual and developmental disabilities, I appreciate the opportunity to comment on the Office of Management and Budget's proposed revisions to the Regulation for Federal Financial Assistance. New Gateways serves individuals who rely on Medicaid-funded and publicly supported services to live meaningful, productive, and inclusive lives within their communities. Like many community-based providers, we operate on extremely narrow financial margins while complying with extensive federal and state oversight requirements. We support responsible stewardship of taxpayer dollars and agree that transparency and accountability are essential. However, we are concerned that several aspects of the proposed rule could unintentionally increase administrative burden and reduce access to critical funding for small nonprofit organizations that deliver direct services. Specifically, we encourage OMB to: Ensure administrative requirements remain proportional. Small nonprofit providers often lack dedicated grant compliance departments. Additional reporting, certification, and documentation requirements divert limited staff time away from providing direct services to individuals with disabilities. Preserve local flexibility. Community providers must respond quickly to the changing needs of the individuals they serve. Excessive federal standardization or centralized decision-making may reduce the flexibility needed to meet local community needs effectively. Recognize the realities facing human service providers. Providers across Michigan continue to experience significant workforce shortages, rising insurance costs, transportation expenses, wage compression, and increasing regulatory requirements. Additional administrative obligations without corresponding funding will further strain organizations already operating under significant financial pressure. Avoid creating barriers to participation. Federal financial assistance should remain accessible to qualified nonprofit organizations. New compliance requirements should not unintentionally discourage smaller organizations from seeking federal funding or force existing providers to withdraw from programs because compliance costs outweigh available resources. Community-based disability providers already operate within a highly regulated environment that includes Medicaid requirements, state licensing standards, person-centered planning, quality assurance reviews, fiscal audits, and extensive documentation expectations. Any new federal requirements should complement—not duplicate—existing oversight systems. Organizations like New Gateways exist because communities need local, trusted providers capable of supporting individuals with disabilities in living full and meaningful lives. Every additional administrative hour is time and resources that cannot be devoted to direct supports, employment preparation, community inclusion, or independent living skill development. We respectfully request that OMB carefully consider the operational realities of small nonprofit service providers when finalizing these regulations. Final regulations should balance accountability with practicality, ensuring that organizations can continue delivering high-quality services while remaining good stewards of public resources. Thank you for the opportunity to provide comments and for your consideration of the needs of nonprofit organizations serving some of our nation's most vulnerable citizens. Sincerely, Lynn Maginity, M.A., QIDP Executive Director/CEO New Gateways, Inc. Waterford, Michigan