The Foraker Group

Today, Foraker submitted comments to the Office of Management and Budget (OMB) urging the agency to withdraw the proposed changes to the Uniform Guidance or substantially revise them through meaningful consultation with nonprofits, municipalities, Tribal organizations, and other stakeholders.

Now it’s your turn. Add your voice to this important conversation. Comments from organizations and individuals can help demonstrate the real-world impact these proposed changes would have on nonprofits and the communities they serve.

The deadline to submit comments is today, July 13.

The Foraker Group is a 501(c)(3) tax-exempt organization serving as Alaska’s nonprofit association and primary technical assistance provider to our state’s nonprofits and tribal organizations. We respectfully submit the following comments to OMB regarding regulations for federal financial assistance.

The Foraker Group strongly opposes proposed changes to federal grant rules for the reasons outlined below. If implemented, changes to the Uniform Guidance will create significant risk and instability for all federal grantees, including nonprofits – not just in Alaska, but across the nation – making it more difficult to provide vital services to communities.

The proposed changes would apply to all federal grants, cooperative agreements, and pass-through awards received by Alaska nonprofits. Since before statehood, Alaska nonprofits have had a long track record of responsive and accountable service as a trusted partner with the federal government, the State of Alaska, and local municipalities. We are such a vital part of everyday Alaska life we are recognized in our state’s constitution. We provide a vast array of programs and services to Alaskans that would otherwise be subject to additional and unnecessary partisan requirements, placing those essential services at risk. Truly, Alaskans rely on nonprofits in many aspects of their lives.

Nonprofits are already highly regulated and comply with myriad requirements and ethical standards – more than any other sector in our society. The proposed OMB changes are unnecessary, misguided, punitive, and stand to end many programs Alaskans depend upon.

We are especially troubled by a myriad of proposed changes that would impact nonprofit operations in the following ways:

• Grant the executive branch seemingly unlimited discretion over federal grants, contrary to federal law and current grant and oversight compliance measures
• Force grantees to operate in a shifting environment, making it more difficult to provide vital services to their communities
• Allow federal agencies to determine discretionary federal awards based on partisan ideology, not community needs or congressional intent, while doing away with the nonpartisan, non-conflicted process of grant review that is currently in place
• Threaten important congressionally funded federal programs that help address longstanding racial, social, or other disparities in underserved communities
• Force nonprofits to choose between applying for critical federal resources and maintaining their deeply held values and beliefs that have served Alaskans for decades
• Discourage nonprofit participation in federal programs, harming the communities those programs were intended to serve

Alaska depends on federal funding, and it is all at risk with these proposed changes. While a vast majority of nonprofits do not receive federal funding directly, those that do stand to lose the most. Still, all nonprofits will feel the effect because Alaska as a whole will be impacted creating more needs, more areas to focus on, and more barriers to overcome. Federal financial assistance that is directly provided to nonprofits impacts services connected to food assurance and security, affordable housing, domestic violence, behavioral health, education, legal assistance, public safety and emergency response, disaster recovery, environmental stewardship, energy development and resilience, and so much more.

Alaska nonprofits receiving federal awards have been willing to be governed by rules that are clear, predictable, fair, and efficient. The proposed changes from OMB will lead to rules that are unclear, unpredictable, financially destructive, inefficient, and most glaringly, highly partisan.

Given the vast integration of nonprofits into the lives of Alaskans, more than in virtually any other state, these concerns are especially acute in our state. We strongly urge you to seriously reconsider your proposed changes to the Uniform Guidance rules.

Respectfully submitted,

The Foraker Group