Comment on OMB-2026-0034-0001
Metis Group IncOpposeBusiness
Summary: Ivana Karina Harrington, President of Metis Group Inc., opposes the immediate reclassification of Subtitle A as binding regulation without a transition period. She argues that this approach creates avoidable noncompliance for existing multi-year awards and recommends applying new requirements prospectively with a defined grace period.
Reclassification to "Uniform Grants Regulation" regarding the transition period
Reclassifying Subtitle A from guidance to binding regulation with a single government-wide effective date provides no transition period for in-flight, multi-year awards.
Recipients mid-performance must conform existing systems, policies, and subawards to new binding requirements without lead time, producing avoidable noncompliance and audit findings in the first cycle.
I recommend to apply new requirements prospectively to awards issued after the effective date and provide a defined grace period (e.g., one full fiscal cycle) for conforming existing policies.
Ivana Karina Harrington, President Metis Group Inc.