Comment on OMB-2026-0034-0001

We are the Ohio Prevention Professionals Association, the membership association for prevention professionals and advocates in Ohio. Our members work in schools, communities, businesses, faith settings, coalitions, and other environments to prevent substance use and mental disorders through evidence-based prevention education, environmental interventions, and other prevention strategies. We are writing in opposition to OMB-2026-0034 (Regulation for Federal Financial Assistance). We have highlighted, below, just a few sections that raise concerns to Ohio’s prevention community. Recognize, however, that we perceive the entire rule as a significant risk to the science-driven work of our members, partners, and the many other prevention professionals, advocates, and systems across the United States. Our concerns include but are not limited to: §200.202. The sentence, “OMB also proposes to clarify that goals and objectives must be consistent with the public purpose of Federal authorizing legislation and aligned with administration policies and priorities,” is chilling. The work of prevention professionals and others in the behavioral health field – and for that matter, any other arena of service to communities – should not be subject to “alignment with administration policies and priorities.” This language eliminates the role of Congress – the people’s representatives – and would prioritize political affiliation or leaning over effective services. §200.205. Our profession is grounded in effective practice, guided by research and evaluation. Allowing political appointees to make funding decisions instead of applying peer-reviewed, science-driven decision-making would be a poor use of taxpayer dollars and would also have a detrimental effect on the children, adults, families, and communities who benefit from evidence-based prevention practice. §200.300. The first paragraph of this section is flush with executive order language. Executive orders are typically temporary by default, changing with each administration. Using executive orders as a foundation for funding decisions would lead to a chaotic environment for funding and programming, less stability in services, and harm to consumers. The implications of this section are an elimination of programming focused on specific populations – a cornerstone of effective prevention practice. We often direct prevention interventions to specific populations based on the effectiveness of the intervention with the population, increased risk for the substance use and/or mental health disorders, and other justifiable factors. To eliminate focused service delivery means programming that may not fit the population, and, ultimately, less efficacy in outcomes. These are just three of the sections that, if they became rule, would cause significant harm to prevention consumers, from early childhood to older adults and individuals, families and communities in between. Prevention science and practice is rooted in reducing risk and building protection and resiliency for our consumers. The totality of this proposed rule would upend the decades of work to build an effective prevention service system in the United States. We implore OMB to withdraw the entire rule, for the sake of prevention consumers and the many others who would be harmed by its enactment. Sincerely, Jim Ryan, OCPC, ICPS Executive Director Ohio Prevention Professionals Association