Comment on OMB-2026-0034-0001

Thank you for the opportunity to provide comments on the Office of Management and Budget’s (“OMB”) proposed rule on Regulation for Federal Financial Assistance, OMB 2026-0034-0001 (the “Proposed Rule”). As Treasurer, I am writing on behalf of the Iowa Public Health Association to express strong opposition to Section 200.340 and 200.205 of the proposed rule under docket OMB-2026-0034. We represent over 100 organizations and 500 members in the State of Iowa, the heartland, the state that feeds not just the nation, but the world, healthy and nutritious foods. We were established in 1925, are an affiliate of the American Public Health Association, and most importantly, we are the voice of public health in Iowa. Our membership represents non-profit organizations, social service agencies, public health departments, and public health professionals who earn a living serving the public, whose purpose is to prevent chronic diseases like cancer and diabetes, promote nutrition education and healthy behaviors, and protect the public’s health from infectious diseases. The changes proposed obligate our organization to share our concern and declare our dissent on behalf of our members and the public good in Iowa. The goals to improve accountability and oversight and prevent misuse are admirable and our organization agrees that those should be priorities, the changes provide opportunities to severely limit the efficiency and impact what the federal dollars, tax payer dollars, are intended for. Our members who are grant recipients responsible for implementing federally funded programs, are deeply concerned that this provision would introduce significant operational, administrative, and financial challenges that will compromise public health outcomes. Our members rely on federal funding to support critical services, including immunization programs, disease surveillance, maternal and child health services and nutrition education, chronic disease prevention initiatives like cancer and diabetes prevention, and behavioral health. These programs require stable funding, timely disbursement, and administrative flexibility to effectively serve our communities. The proposed changes in [200.205] would allow political appointees to evaluate funding proposals for policy alignment rather than be awarded on merit, feasibility, and impact on public health. Introduction of this bias compromises programs that support the health of the nation. The proposed changes in [200.340] expands agency authority to terminate or suspend grants based on vague determinations with limited explanation. Several federal funding sources are multi-year for good reason, to achieve programmatic goals, reach stabilization, and support sustainability. Agencies administering these critical health programs need to have a sense of stability. The uncertainty that a program’s funding could be terminated without a clear and objective reason discourages administration and disrupts long-term gains the public health system of the nation has achieved. It will lead to lower recruitment and retention, and overall disrupt the workforce to sustain these programs. Overall, Congress has the power of the purse. A strict constitutionalist would decry this overreach by any federal agency. Granting the very agencies charged with carrying out Congress's directives the authority to terminate funding undermines the safeguards in place to protect citizens' interests. Pre-issuance review is bureaucracy on steroids. Thank you for the opportunity to provide critical feedback on these potential and disastrous changes.