Comment on OMB-2026-0034-0001

Our organization receives USDA/ BFRDP funding to provide technical assistance, education, and information resources to beginning farmers and producers across our rural region. After reviewing the proposal, I am unable to determine whether these provisions apply to my agreement or what requirements would apply if they do. OMB should clearly identify which USDA programs, agreements, and funding arrangements are covered and explain how participants can determine their obligations. To provide this assistance to our farmers we talk with beginning farmers over the phone and by email to gather information about obstacles to their success, and make in-person visits to farms to understand first-hand their challenges and issues. We pay farmer mentors, bookkeepers, and other consultants to assist farmers on a 1:1 basis to address problems that can vary from irrigation systems set-up, to developing a plan for succession planting of seasonal vegetables to setting up QuickBooks, to effective product merchandising and best practices for social media outreach. Over the three-year span of the BFRDP grant, we will work with over 60 farmers and consultants in 1:1 consultations, and bring together more than 150 farmers in networking events. We are concerned that the proposal could make it more difficult to maintain these partnerships because it increases our oversight responsibilities of partners (§§ 200.330–332) while restricting fixed-amount subawards (§ 200.333) and relying on terms that are not clearly defined. For example, it is unclear how we would be expected to interpret and comply with standards such as "elevated programmatic risk," (§ 200.208) "activities inconsistent with federal civil rights laws," (§ 200.330) or actions that could damage the reputation of the federal government (§ 200.332). MB should provide clear definitions, examples, and implementation guidance so organizations like ours can confidently comply with program requirements while continuing to work effectively with local partners. We are also concerned that the proposal could increase administrative and compliance costs while also allowing USDA to impose additional conditions after an award has already been made. For example, additional documentation requirements (§ 200.302, § 200.305), reimbursement procedures (§ 200.208), monitoring obligations (§ 200.329), or approval requirements (Subpart E) could require us to divert staff time away from direct farmer support and toward compliance activities. It is also unclear what circumstances could lead USDA to determine that our organization or program presents elevated risk and impose new conditions during the project (§ 200.208). OMB should explain how these risk determinations will be made, what protections recipients will have, and how smaller organizations are expected to absorb increased administrative costs while continuing to serve farmers and rural communities.