HomeMy WebLinkAboutLetter of Support for Association of Washinton Cities Response OMB-2026-0034
July 31, 2026
Sent via email Maria_Cantwell@cantwell.senate.gov
Sent via email Senator_Murray@murray.senate.gov
Sent via email Emily.Randall@mail.house.gov
Re: Letter of Support for Association of Washinton Cities Response OMB-2026-0034, Office of Management
and Budget (OMB) Regulation for Federal Financial Assistance
Dear Senator Cantwell, Senator Murray, and Representative Randall,
On behalf of the City of Port Angeles, we urge you to highly consider the comments submitted from the
Association of Washington’s Cities (AWC) on the proposed rule changes outlined in Docket OMB 2026-0034.
Port Angeles is amongst many other Washington cities that have serious concerns over several of the proposed
changes. In particular, how many of these changes could impact the ability to access and manage federal
funding moving forward, especially given the quickly approaching October 1, 2026, implementation deadline.
The proposal's potential to increase compliance costs, reduce local flexibility, and create uncertainty and risk
around awarded federal funds jeopardizes opportunities for cities to use grant funding on necessary projects that
have the potential to go unfunded. Therefore, we urge you to consider the list of oppositions and concerns
provided by AWC. However, not all of the proposed changes have negative impacts. The City of Port Angeles
supports transparency and accessibility efforts wholeheartedly. We also support the following provisions that
propose to make it easier for cities to apply for and manage federal grants, including:
• Plain language NOFOs
• Greater use of Grants.gov
• Using statements of interest
• Shorter NOFO exec summaries
• Longer application periods.
• Broader applicant access
Washington cities support efforts to simplify federal grant processes, but we urge OMB to reconsider provisions
that would increase administrative burdens, introduce uncertainty, and expand federal control over local
decision-making. We appreciate the work that you do to help Port Angeles be the best that it can be. Thank you
for your time and consideration.
Sincerely,
Kate Dexter
Mayor
Cc: City Council, City Manager, Catalina Amortegui Catalina_Amortegui@murray.senate.gov, Paul Quinonez
Figueroa paul_quinonez@cantwell.senate.gov, April Messenger April.Messenger@mail.house.gov
Attachment: AWC Letter
321 East Fifth Street
Port Angeles, WA 98362
Docusign Envelope ID: AFFFD53B-91C3-8C4D-82D9-9BB261168A31
July 1, 2026
Honorable Russell T. Vought
Director
Office of Management and Budget
725 17th Street NW
Washington, D.C. 20503
Re: OMB-2026-0034, Office of Management and Budget (OMB) Regulation for Federal Financial Assistance
Dear Director Vought:
Thank you for the opportunity to provide comments on the proposed rule changes outlined in Docket OMB-
2026-0034. I’m writing on behalf of Washington cities to urge your reconsideration of some of the proposed
rules revising the OMB Guidance for Federal Financial Assistance.
Washington cities have serious concerns about how some of these changes could impact the ability to access
and manage federal funding moving forward, especially given the quickly approaching October 1, 2026,
implementation deadline.
After a thorough read-through, we believe some of the most impactful changes will:
1. Increase the administrative burden on cities and towns;
2. Create more uncertainty around federal grants because of issues like mid-award grant terminations,
thereby increasing risk for local governments to accept federal funds; and
3. Politicize federal grantmaking rather than allowing agencies to rely on the statutes provided to them by
Congress.
For Washington cities, the biggest issue is not the application process or the grant requirements, but rather the
proposal's potential to increase compliance costs, reduce local flexibility, and create uncertainty and risk
around awarded federal funds. Furthermore, Washington cities, which are historically excellent fiduciaries of
federal funds, already meet stringent reporting requirements and are subject to in-depth audits of public dollars
via the State Auditor’s Office.
However, there are some provisions in the proposed rule changes that cities support, such as increasing
accessibility to the application process. You can read more about our position on specific provisions within this
comment letter.
Provisions cities oppose
1. Cities oppose increased administrative burden on communities.
Federal grants are already a major undertaking that require consistent attention at every step, from
application and management to reporting and compliance verification. OMB’s proposed changes would
further increase these burdens without providing additional resources or funding or specifying how priorities
will be measured. Adding new steps to the compliance and reimbursement process for federal grantees
would be particularly troublesome for small and under-resourced communities.
We oppose the following changes:
• Requiring all payment requests from cities to include written justifications describing the purpose of
each payment and the specific award-related work it supports.
• Granting agencies the authority to add or remove specific conditions throughout the performance
period based on “risk factors” or “other factors” associated with a recipient or program, without
providing specific guidance on what those factors are.
• Requiring all recipients and subrecipients of federal financial assistance to participate in the
Department of Homeland Security’s E-Verify program for work associated with federal grants.
• Extending Buy America-style provisions beyond infrastructure to all federal awards regardless of
domestic production capacity.
• Requiring states to run pre-payment checks through Treasury’s Do Not Pay (DNP) system before
disbursing pass-through funds, which may delay access to funds for both local governments and
residents.
• Discouraging cost-reimbursement contracts between grant recipients and their vendors or
contractors (e.g., engineering firm, contractor). Local governments must submit a written justification if
they want to use a cost-reimbursement contract.
2. Cities oppose making federal funding more uncertain and unwieldy.
Federal grant funding is already an uncertain and unwieldy resource for communities. Many cities pay
federal grant writers to compete for awards that may not even be selected. When they are, grant
agreements can take two or more years to be finalized. Grant reimbursements for local governments can
already be frozen during federal government shutdowns. OMB’s proposed changes would introduce
additional uncertainty by allowing awards to be modified or terminated based on shifting Executive Branch
priorities, even when recipients are meeting program objectives and have made significant local
investments. This would create a greater degree of risk for award recipients, especially those with limited
resources to manage such risk, and would likely reduce the number of cities willing to seek much-needed
funding.
We oppose the following changes:
• Allowing federal agencies to terminate a grant award during the period of performance if it is
determined that the award no longer aligns with program goals or Executive Branch policies in effect at
the time of termination.
• Preventing individual agencies from exercising discretion in grant compliance or making
reasonable accommodation for conditions not anticipated by statute.
• Requiring pass-through entities to ensure their subrecipients do not take actions that could
significantly damage the reputation of the pass-through entity, the federal agency making the award, or
the federal government.
• Eliminating fixed amount awards and subawards.
3. Cities oppose increasing the risk of politicizing federal grantmaking.
Federal grantmaking should be consistent, transparent, and accessible to all eligible communities, with
clear policy goals and measurable outcomes. Several provisions raise concerns that decisions could
become more subjective or politically influenced rather than grounded in objective policy criteria.
We oppose the following changes:
• Allowing federal agencies to consider an applicant’s “history of questionable practices” when
deciding their eligibility for a grant. OMB does not provide guidance on what “questionable practices”
means, allowing individual federal agencies and compliance officers wide latitude on how to enforce.
• Permitting federal agencies to cooperate with private individuals or organizations in pursuing
their own private cause of action or remedies for grant noncompliance.
• Expecting recipients to adapt to Executive Orders, even when those directives are not codified in
law and may change over the course of a grant’s performance period.
• Introducing “pre-issuance review,” which means that, as part of the broader merit review process,
political appointees at each agency, rather than career experts, will ensure that proposals selected for
funding are consistent with applicable law, federal agency priorities, and the national interest.
• Requiring cities that receive federal funding (including as subrecipients) not discriminate based on
the viewpoint, content, or subject matter of speech including political, ideological, or religious affiliation
or perspective in providing services for events, meetings, or other expressive activities, regardless of
whether those activities are federally funded.
Provisions cities support
Improving transparency and accessibility are laudable goals. We support certain provisions that propose to
make it easier for cities to apply for and manage federal grants, including:
• Plain language NOFOs: Reinforcing the requirement that Notices of Funding Opportunities (NOFOs)
should be written in “plain language.”
• Greater use of Grants.gov: Requiring that applicants apply for federal grants using Grants.gov unless
a program-specific exception is expressly authorized.
• Using statements of interest: Encouraging agencies to use Statements of Interest (SOIs) as part of
the application process when high application volume or lengthy proposals are expected.
• Shorter NOFO exec summaries: Requiring executive summaries (generally limited to 500 words) in
NOFOs, with limited exceptions.
• Longer application periods: Requiring NOFOs to be posted for at least 30 days.
• Broader applicant access: Encouraging agencies to strive to ensure that NOFOs are accessible to a
broad range of applicants, including those that have not previously received federal awards.
Washington cities support efforts to simplify federal grant processes, but we urge OMB to reconsider
provisions that would increase administrative burdens, introduce uncertainty, and expand federal control over
local decision-making. Thank you for considering this input.
Sincerely,
Candice Bock
Government Relations Director
Association of Washington Cities