Comment on OMB-2026-0034-0001
Metis Group Inc.SupportBusiness
Summary: Ivana Karina Harrington, President of Metis Group Inc., supports the proposed regulation but requests specific clarifications regarding payment timing. She argues that recipients should not be held liable for interest or "minimize-cash-on-hand" obligations during delays caused by the agency's suspension authority or review processes.
§200.305 Payment & cash management and drawdown timing
Payment-timing requirements are challenging with the new suspension authority and pre-issuance review delays.
Recipients caught between minimize-time-on-hand rules and frozen drawdowns face liquidity gaps and interest-liability ambiguity.
I recommend providing clarity to minimize-cash-on-hand obligations that are tolled during agency-caused payment delays, and that no interest liability accrues for agency-side holds.
Ivana Karina Harrington, President Metis Group Inc.